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Vora End-User Terms (Participants)

Version: 3.2.1 Effective Date: 13 May 2026 Last Updated: 26 May 2026 Authoritative Language: Italian. This English version is a courtesy translation of end-user-tos.it.md. In case of any conflict, the Italian version prevails.

Who these Terms apply to

These End-User Terms (the "Terms") govern the use of the Vora platform (the "Platform") by natural-person end users accessing the public spaces of customer organisations (the "Organisations" or "Promoters") to:

The Platform is provided by Vora S.r.l., an Italian-law company with registered office at [REGISTERED OFFICE ADDRESS], Tax Code and VAT no. [VAT: ____] (the "Company" or "we"). The Platform is, however, technically accessible globally and hosts Organisations established in numerous jurisdictions; these Terms adopt an Italian-prevailing posture but recognise End-User rights equivalent to those granted under the laws applicable in the user's habitual residence.

If you use the Platform for purposes connected to your professional, business, artisan, or institutional activity, the Customer Terms (B2B) apply instead - see customer-tos.en.md.

1. Vora is a technology platform - who is responsible for the initiative

1.1 Vora is a technology platform. The Company provides solely the software infrastructure that enables Organisations to collect ideas, manage voting and distribute rewards.

1.2 Every initiative published on Vora (idea collection, voting, Idea Challenge, prize distribution) is organised, managed and promoted exclusively by the Organisation owning the space in which you participate. This Organisation is the "Promoter" / "Sponsor" / "Organisateur" / "Veranstalter" / "Organizador" within the meaning of the applicable law in its jurisdiction (for Italian Promoters, under Article 5 of Italian D.P.R. 26 October 2001 no. 430; for the United States, under the FTC Act and state laws; for the United Kingdom, the Gambling Act 2005; for Germany, § 657 BGB and the UWG; for Brazil, Lei 5.768/1971; etc.).

1.3 The Company, as a hosting-service provider under Article 16 of Italian Legislative Decree 9 April 2003 no. 70 and Article 6 of Regulation (EU) 2022/2065 ("DSA") and under substantially equivalent principles in other legal systems (47 U.S.C. § 230 in the US; Online Safety Act 2023 in the UK; Brazilian Marco Civil da Internet Lei 12.965/2014 Articles 18-19), does not act:

a) in the selection of winners;

b) in the drafting of contest rules;

c) in the delivery of prizes;

d) in the evaluation of the quality of ideas or contributions.

1.4 For complaints, requests for clarification or contests relating to a specific initiative (rules, outcome, prize delivery), your point of contact is the Promoter, whose contact details are published in the Organisation's space on the Platform. The Company may provide technical support for forwarding the communication but does not intervene on the merits.

2. Registration and Account

2.1 Active participation in a vote, submission of an idea and receipt of a Reward require creation of a Vora account. Registration is free and may be done via email/password or Google Sign-In (OAuth 2.0).

2.2 Minimum age - "highest applicable threshold" rule. The user warrants having reached the applicable minimum age based on their habitual residence both to:

a) consent to the processing of personal data; and b) conclude the Platform usage contract.

Where habitual residence and/or applicable law set distinct thresholds for the two profiles (digital consent vs. contractual capacity), the higher of the relevant thresholds applies. Examples (non-exhaustive list):

2.3 Minors who do not meet the required threshold may use the Platform only with verifiable consent of the holder of parental responsibility, collected and managed by the Promoter Organisation. The Company does not collect parental consents on its own behalf. In case of accidental collection of data of children under 13 in breach of COPPA, the Company proceeds to delete the data within 30 days of becoming aware of the event.

2.4 The user further warrants: (a) to provide accurate, true and up-to-date personal data; (b) not to create multiple accounts in order to manipulate votes or Idea Challenge outcomes.

2.5 The user is responsible for safekeeping of their credentials and for any use of the account, save in cases of unauthorised third-party access promptly notified to the Company.

2.6 The Company may suspend or close the account in case of breach of these Terms or of the Acceptable Use Policy acceptable-use.en.md, upon notice and where possible granting a remediation deadline.

3. User-Generated Content (UGC) - Licence

3.1 The user retains ownership of content uploaded to the Platform (idea text, attached images, proposal descriptions, comments). The Company makes no proprietary claims to user content.

3.2 By uploading content, the user grants:

a) to the Promoter (the Organisation owning the space) a non-exclusive, free, worldwide licence, irrevocable for the time necessary to manage the initiative, to use, reproduce, display, evaluate the content solely for the purpose of running the initiative and communicating results;

b) to the Company a non-exclusive, free, worldwide licence, limited to the technical provision of the Service (storage, indexing, presentation to other users, blockchain certification of the vote associated with the content, backup and security operations).

3.3 The user represents and warrants to be the original author of the content, or to hold all necessary rights (including image releases under Article 96 of Italian Law 633/1941 and Article 10 of the Italian Civil Code and/or equivalent protections in other jurisdictions - U.S. right of publicity, French droit à l'image, etc., if the content depicts persons), and not to infringe third-party rights (intellectual property, privacy, image, personal data) by uploading.

3.4 The user may request removal of own content at any time; removal takes effect from the time of the request and does not affect security backup copies or vote data already certified on blockchain, whose immutability is described in Article 5.

3.5 Optional promotional and social-media permission. Separately and in addition to the licences in Article 3.2, where you choose to add your personal social-media links (for example Instagram, TikTok, X/Twitter, YouTube or a website) to your profile and you give your specific opt-in permission, you grant the Company and the organisation running the relevant Idea Challenge or space (the "Promoter") a non-exclusive, royalty-free, worldwide and revocable permission to mention, tag, link, share, re-share and feature your name or handle, your submitted idea (title and images) and your public profile on the Company's and the Promoter's own official social-media and communication channels, for the limited purpose of promoting the Platform and the relevant Idea Challenge or space. This permission also constitutes, to the extent your submitted content depicts you, your consent to the publication of your image for these promotional purposes under Article 10 of the Italian Civil Code and Articles 96 and 97 of Italian Law no. 633 of 22 April 1941, and the equivalent image and publicity rights of your jurisdiction.

3.6 This permission is optional and is not a condition for submitting an idea, voting or participating. You may give it or refuse it freely, and you may withdraw it at any time by removing your social-media links from your profile or by writing to privacy@voiceofthenewera.com. Withdrawal operates for the future only: it does not affect the lawfulness of promotional uses made before withdrawal and does not oblige the Company to delete content already published on third-party social-media platforms, on which the Company will nonetheless use reasonable efforts to remove or untag the relevant material upon your request. The legal basis for this processing is your consent under Article 6(1)(a) GDPR, and the equivalent bases of applicable laws.

3.7 You represent that the social-media accounts you provide belong to you or that you are authorised to use them, and that featuring your submitted content does not infringe third-party rights.

4. Acceptable Use - What is Prohibited

4.1 The user undertakes not to upload, publish or transmit through the Platform content that is:

a) illegal, defamatory, slanderous, insulting, obscene, pornographic, or harmful to personal dignity;

b) constituting incitement to hatred, violence, racial, ethnic, religious, gender or sexual-orientation discrimination (Italian Law 25 June 1993 no. 205 and Article 604-bis of the Italian Criminal Code, and equivalent rules of applicable jurisdictions);

c) constituting terrorist propaganda (Regulation (EU) 2021/784 and Italian Decree-Law 18 February 2015 no. 7, and equivalent rules - UK Counter-Terrorism Act, 18 U.S.C. § 2339B in the US, etc.);

d) child sexual abuse material (CSAM - Article 600-ter of the Italian Criminal Code; 18 U.S.C. § 2252; equivalent rules);

e) infringing third-party copyright, trademark, patent or other intellectual property rights;

f) containing third-party personal data without an appropriate legal basis;

g) malware, malicious code, phishing links, content compromising Platform security;

h) attempts at voting manipulation (multiple accounts, bots, vote-buying schemes).

4.2 The complete list of prohibited content and the reporting procedure are detailed in the Acceptable Use Policy acceptable-use.en.md.

4.3 To report illegal content on the Platform, a notice-and-action procedure is available under Article 16 of Regulation (EU) 2022/2065 ("DSA") and equivalent principles of applicable jurisdictions (UK Online Safety Act 2023, German NetzDG, Brazilian Marco Civil):

5. Vote Immutability and Blockchain Certification

5.1 Every vote cast on the Platform is recorded in an audit log certified on a public blockchain network (distributed register Base L2 for Starter, Growth and Pro plans; Ethereum Mainnet for Enterprise plans of individual customers).

5.2 The certification produces an immutable record of the fact that a vote was cast, with its timestamp and an integrity hash. It is technically impossible to retroactively delete or modify the blockchain record.

5.3 Practical consequences for the user:

a) the vote, once confirmed by the Platform and sent to the certification queue, cannot be withdrawn (reconsideration after confirmation is not permitted);

b) submission of a contribution to an Idea Challenge is final: the contribution may be withdrawn by the author before challenge closing, but if already voted, the vote remains recorded on the blockchain;

c) the user may independently verify the registration of their vote by consulting the public endpoint https://api.voiceofthenewera.com/api/v1/verify/<vote_hash>/ or the verification tool accessible from the results page of each proposal.

5.4 The blockchain records only cryptographic digests (keccak256) of the votes, not the user's identity nor any personal data in clear. The connection between on-chain hash and user identity is kept off-chain in the Company's systems, accessible only within the limits set out in the Privacy Policy privacy-policy.en.md.

5.5 The user may nevertheless exercise the GDPR rights (and the equivalent rights under other applicable laws) referred to in Article 7 below, including the right to deletion of off-chain personal data; this does not affect the integrity of the on-chain audit log, which is free of direct identifiers and contains only cryptographic hashes (qualifying as non-personal data under Italian DPA practice and analogous guidance on blockchain).

6. Rewards, Prizes and Tax Aspects

6.1 Where the initiative provides for Rewards or prizes, the Promoter defines: (a) the award rules; (b) the nature of the good/service; (c) delivery modalities; (d) timelines.

6.2 Any tax withholding (in Italy, 25% under Article 30 of D.P.R. 600/1973; in the US, IRS Form 1099-MISC for prizes ≥ USD 600; in other jurisdictions, per local law) is applied and paid by the Promoter in its capacity as withholding agent / substituto d'imposta / responsible party. The Company makes no withholding nor issues Certificazione Unica, Form 1099 or equivalent tax documentation on behalf of the Promoter.

6.3 The winning user is invited to verify with the Promoter the modalities for issuing the receipt, the prize-acceptance declaration and any other required fulfilment.

6.4 In case of failure to deliver the prize, delay or defect, the complaint must be forwarded directly to the Promoter. The Company may provide technical assistance only to recover evidence of the user's registration as a winner on the Platform, where such evidence is still available.

7. Data Subject Rights (GDPR and equivalent laws)

7.1 The user is informed that their personal data are processed by the Company and/or the Promoter as described in the Privacy Policy privacy-policy.en.md, which complements these Terms.

7.2 The user resident in the European Union / EEA may exercise the rights under Articles 15-22 GDPR:

7.3 The user resident in the United Kingdom has substantially equivalent rights under UK GDPR and the Data Protection Act 2018.

7.4 The user resident in California has the rights under CCPA / CPRA (Cal. Civ. Code §§ 1798.100 et seq.): - right to know what data are collected and for what purposes; - right to delete; - right to correct; - right to opt out of "sale" or "sharing" of personal information - the Company declares that it does NOT sell or share personal information within the meaning of Cal. Civ. Code § 1798.140; - right to non-discrimination for exercising CCPA rights.

7.5 The user resident in Brazil has the rights under Article 18 LGPD (Lei 13.709/2018): confirmation of processing existence, access, rectification, anonymisation/deletion, portability, information on sharing, objection, withdrawal of consent.

7.6 The user resident in other jurisdictions (Canada - PIPEDA; Australia - Privacy Act 1988; Switzerland - FADP; etc.) has substantially equivalent rights under applicable law.

7.7 Requests must be addressed:

a) to the Promoter (as controller) for data collected within a specific initiative;

b) to the Company at privacy@voiceofthenewera.com for data relating to the account and general Platform use.

7.8 In case of rights infringement, the user may file a complaint with the competent supervisory authority of their habitual residence, including by way of example:

8. The Company's Limitation of Liability

8.1 The Company is not liable, within the limits permitted by law, for:

a) failure to deliver, delay in delivery or defect in prizes awarded by the Promoter;

b) the legitimacy of the initiative rules and their compliance with prize-contest regulations (D.P.R. 430/2001 in Italy, Gambling Act 2005 in the UK, FTC Act and state laws in the US, Lei 5.768/1971 in Brazil, etc.);

c) the quality, accuracy or veracity of content uploaded by other users;

d) Platform interruptions due to force majeure, maintenance, cyber-attacks;

e) indirect damages, loss of chance, loss of profit.

8.2 The Company's liability remains intact for wilful misconduct or gross negligence under Article 1229 of the Italian Civil Code and for the consumer's mandatory rights under Italian Legislative Decree 6 September 2005 no. 206 ("Italian Consumer Code") and equivalent consumer-protection rules of applicable jurisdictions (UK Consumer Rights Act 2015, US Magnuson-Moss Warranty Act, Brazilian Código de Defesa do Consumidor, etc.).

9. Forum, Governing Law and Consumer Protection by Jurisdiction

9.1 EU / EEA consumers. For users acting outside their commercial, business, artisan or professional activity (consumers within the meaning of Article 3 of the Italian Consumer Code and EU/EEA equivalent definitions), the mandatory consumer forum applies under Articles 17-19 of Regulation (EU) 1215/2012 (Brussels I-bis) and Article 33(2)(u) of Italian Legislative Decree 206/2005: the consumer may sue the Company in their Member State of residence and may be sued only in their Member State of residence. The law applicable to consumer disputes is governed by Article 6 of Regulation (EU) 593/2008 ("Rome I"), which guarantees the consumer the mandatory protections of the state of habitual residence.

9.2 UK consumers. The mandatory protections of the Consumer Rights Act 2015 (in particular the unfair terms regime in Part 2) and the UK post-Brexit conflict-of-laws rules apply; in particular, vexatious clauses in consumer contracts with UK consumers are void to the extent they fail the fairness test of the Consumer Rights Act.

9.3 California consumers (US). The mandatory protections of CCPA / CPRA (Cal. Civ. Code §§ 1798.100 et seq.) apply as described in Article 7.4. The California consumer may bring claims before California courts for disputes concerning CCPA rights, without prejudice to arbitration under Article 9.7 where applicable.

9.4 Brazilian consumers. The mandatory protections of the Código de Defesa do Consumidor (Lei 8.078/1990) and LGPD (Lei 13.709/2018) apply. The Brazilian consumer may bring claims in their domicile forum.

9.5 Consumers in other jurisdictions. Residually, the mandatory protections of the law of the user's habitual residence apply.

9.6 Users acting as professionals. For disputes with users acting as professionals, the competent forum is set out in the Customer Terms (B2B) customer-tos.en.md, Article 13.

9.7 Residual governing law. Without prejudice to the mandatory consumer rights, the law applicable to these Terms is Italian law, excluding conflict-of-laws rules.

9.8 Online dispute resolution (ODR) for EU consumers. The consumer user may use the European online dispute-resolution platform under Regulation (EU) 524/2013, accessible at ec.europa.eu/consumers/odr.

9.9 Consumer mediation in other jurisdictions. The consumer user may approach consumer-protection bodies of their jurisdiction (e.g., Better Business Bureau in the US, Citizens Advice in the UK, Procon in Brazil, etc.).

10. Amendments to the Terms

10.1 The Company may amend these Terms; the new version is published at voiceofthenewera.com/end-user-terms.it.html with at least thirty (30) days' advance notice before the effective date, save for legally mandated amendments with immediate effect.

10.2 Material amendments are notified by email to registered users. Continued use of the Platform after the effective date constitutes acceptance; alternatively, the user may close the account at no cost.

10.3 Versioning is recorded per user in the tos_version_accepted field.

11. Contacts

11-bis. International Sanctions and Access Restrictions

11-bis.1 In accordance with the Customer Terms (B2B) Article 13-bis, access to the Platform may be limited or suspended for users located in jurisdictions subject to comprehensive economic sanctions (as at v3.1.0: Iran, North Korea, Syria, Cuba, Crimea, Donetsk, Luhansk, Zaporizhzhia, Kherson; and, for uses falling within the scope of Regulation (EU) 833/2014 and Regulation (EU) 765/2006, Russia and Belarus).

11-bis.2 the Company may also suspend or close the user's account where it detects that the user, or their documented identity, is included in applicable sanctions lists (OFAC SDN, UK OFSI, EU 269/2014, UN SC, etc.).

11-bis.3 This measure is taken for the strict purpose of complying with the sanctions obligations applicable to the Company as an Italian-law company and Platform operator.

Source document in markdown: docs/legal/end-user-tos.en.md (v3.1.0 - 13 May 2026).