Distance Sales Agreement and Pre-Contractual Information for Consumers

This Agreement governs subscriptions to the Astramio platform purchased online by a consumer, that is, a natural person acting for purposes outside their trade, business or profession. It is drafted under the Turkish Consumer Protection Law No. 6502 ("Law 6502") and the Regulation on Distance Contracts, and it also states the additional protections that apply if you are a consumer resident in the European Economic Area or the United Kingdom.

If you are buying for a business, whether a company, sole trader, freelancer acting professionally or public body, consumer law does not apply to you and your purchase is governed by the Astramio Terms of Service instead of this Agreement. Article 12 below still applies to everyone.

The pre-contractual information required by Article 5 of the Regulation on Distance Contracts is contained in Articles 1, 3, 4, 5, 6, 7 and 10 of this Agreement and is shown to you on the order page before you confirm payment. This Agreement, together with our full registration details, is sent to you on a durable medium by email with your order confirmation.

Article 1 – Parties

1.1. Seller / Service Provider

1.2. Buyer

The natural person whose name, address, email address and telephone number are entered during the order process and shown in the order confirmation ("you" or the "Buyer"). You confirm that this information is accurate and that you are at least 18 years old.

Article 2 – Subject and formation

2.1. This Agreement covers the sale of a subscription to the Astramio platform and the Mio assistant, a cloud-hosted software service ("SaaS") for creating, scheduling, publishing and analysing brand and social-media content, in the plan and billing period you selected on the order page (the "Service").

2.2. The Service is a digital service supplied continuously over the subscription period. It is not a one-off download and is not supplied on a tangible medium.

2.3. The Agreement is formed when you click the order button on the order page, having reviewed this Agreement and the pre-contractual information, and we confirm your order by email. Clicking the button creates an obligation to pay, and the button is labelled accordingly.

2.4. We store the concluded Agreement and your order details and send you a copy by email. You can also access the current version of this Agreement at any time on our website.

Article 3 – Price, taxes and payment

3.1. The total price of your plan, including all taxes and any set-up fees, is shown on the order page before you confirm. There are no hidden charges.

3.2. Prices are shown in the currency indicated on the order page. For buyers in Türkiye that is Turkish lira (TRY) and the price includes VAT at the applicable rate. For buyers elsewhere, the order page states the currency and whether VAT or an equivalent tax is added, before you pay.

3.3. You can pay by:

• credit or debit card through our payment processor, a provider licensed for payment services and certified to the PCI DSS standard; card details are entered on the processor's secure form and never stored by Astramio; or
• bank transfer (EFT or wire) for annual plans, where offered on the order page.

3.4. Recurring billing. Subscriptions renew automatically at the end of each billing period, monthly or annual, at the then-current price for your plan, and the payment method on file is charged at each renewal, until you cancel. You give your express, affirmative consent to this recurring charge on the order page by ticking an unticked box. We keep a record of that consent.

3.5. Price changes are at our discretion. Our prices are not fixed for the future and are not guaranteed to stay the same. We may change the price of any plan at any time, at our sole discretion. A price change never affects a billing period you have already paid for. It applies from your next renewal onwards, and we tell you by email at least 30 days before that renewal date. If you do not want to pay the new price, cancel before the renewal date; if you do not cancel, the renewal at the new price is treated as your acceptance of it.

3.5.1. Promotional, launch, trial and discounted rates apply only for the period stated at the time of purchase. Unless we say otherwise, they renew at the standard rate for your plan.

3.6. Renewal reminders. Before every renewal we email you a reminder stating the renewal date, the amount that will be charged and how to cancel. For annual plans we send it between 15 and 45 days ahead, and for monthly plans at least 3 days ahead.

3.7. Invoices. An electronic invoice (e-Arşiv) is issued for each payment and sent to your email address.

3.8. Promotions. Where we advertise a price reduction, we show the lowest price we charged for the same plan in the 30 days before the reduction. We do not personalise prices based on automated profiling; if we ever do, the order page will say so.

Article 4 – Delivery and activation

4.1. The Service is delivered digitally. It is activated immediately after payment is confirmed, and you access it by signing in to your account at app.astramio.com. No physical goods, licence keys or download links are provided.

4.2. If we cannot activate the Service, we will tell you within 3 days of learning of the problem and refund any payment within 14 days of that notice.

4.3. We aim to keep the Service available continuously. Short interruptions for maintenance, updates and infrastructure improvements may occur; where planned, we announce them in advance. Any service-level commitments for paid plans are set out in the Terms of Service and apply in addition to your statutory rights under Article 8.

Article 5 – Right of withdrawal

Your withdrawal rights depend on where you live. Please read the paragraph that applies to you. In every case, withdrawal is exercised by a clear statement to us, for example by email to [email protected] or by using the cancellation option in your account settings. You may use the model form in the Annex but you do not have to.

5.1. Consumers resident in Türkiye

5.1.1. Under Article 15(1)(ğ) of the Regulation on Distance Contracts, the right of withdrawal does not apply to services performed instantly in an electronic environment, and under Article 15(1)(h) it does not apply to services whose performance began, with the consumer's approval, before the withdrawal period ended.

5.1.2. The Service is activated instantly and continuously performed from the moment of payment. Before you order, we ask you to acknowledge, by ticking a separate unticked box, that performance begins immediately at your request and that you therefore lose the 14-day right of withdrawal. If you do not tick that box, activation is deferred until the end of the 14-day period and you keep the right to withdraw during that period.

5.1.3. Losing the right of withdrawal does not affect your right to cancel the subscription under Article 6, or your statutory remedies for a defective service under Article 8.

5.2. Consumers resident in the European Economic Area

5.2.1. You have the right to withdraw from this Agreement within 14 days of the day it is concluded, without giving any reason, under Article 9 of Directive 2011/83/EU. The Service is a digital service rather than digital content, so the exception for digital content in Article 16(m) of the Directive does not apply, following the Court of Justice of the European Union in Case C-234/25 of 9 July 2026.

5.2.2. If you ask us to start the Service during the withdrawal period, which we ask you to request expressly on the order page, and you then withdraw, you pay only a proportionate amount for the Service supplied up to the moment you informed us of your withdrawal, calculated against the total price of the billing period, under Article 14(3) of the Directive. We refund the balance within 14 days of receiving your withdrawal notice, using the same payment method you used.

5.2.3. If you do not ask for immediate start, the Service is activated after the withdrawal period ends and a withdrawal during that period results in a full refund.

5.2.4. The withdrawal right arises when you first subscribe. An automatic renewal continues the same subscription rather than concluding a new contract, so it does not start a new 14-day period and is not refundable under this Article.

5.3. Consumers resident in the United Kingdom

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 give you the same 14-day right as described in 5.2, with the same proportionate-payment rule where you asked for the Service to start within the cancellation period.

5.4. Consumers resident elsewhere

You have the rights in 5.1 unless the mandatory consumer law of your country of residence gives you more.

Article 6 – Duration, cancellation and termination

6.1. Term and renewal. Your subscription runs for the billing period you chose and renews automatically for a further period of the same length, as set out in Article 3.4, until you cancel it.

6.2. You can cancel at any time, yourself, in the app. Cancel from the subscription settings inside your Astramio account. Cancelling takes no more steps than subscribing did, you do not need to contact us, and you do not need to give a reason. If you would rather write to us, email [email protected]. We confirm every cancellation by email within 3 business days.

6.3. What cancellation does, and no refunds for the period in progress. Cancellation stops the next renewal. You keep full access for the remainder of the billing period you have already paid for, and the subscription ends when that period ends. Fees already paid are not refunded, in whole or in part. We do not give partial, pro-rata, unused-time or goodwill-as-of-right refunds for a period in progress, whether you cancel on the first day of the period or the last, and whether or not you used the Service during it. This applies equally to monthly and annual plans, including immediately after an automatic renewal.

6.4. The refunds consumer law still requires. Article 6.3 does not affect the following, which we honour in every case:

• (a) withdrawal from your first purchase if you are an EEA or UK consumer, under Article 5.2 or 5.3;
• (b) a proportionate price reduction or a refund for the non-conforming period if the Service does not conform and we do not put it right, under Article 8.2;
• (c) a refund of the unused part of the period if we terminate for our own convenience under Article 6.5, if we change this Agreement or the Service to your material detriment and you terminate for that reason, or if an event outside our control makes the Service substantially unavailable for more than 14 consecutive days under Article 8.3.

Separately, we always refund a payment that was taken in error, taken twice, taken without your authorisation, or taken after you had already cancelled. We may also make a refund as a goodwill gesture when we think it is fair. Doing so once does not oblige us to do it again and does not change Article 6.3.

6.5. Termination by us. We may suspend or terminate the Service if you materially breach this Agreement or the Terms of Service, for example through unauthorised access, misuse of AI features to produce unlawful content, or infringement of third-party rights, and do not cure the breach within 14 days of notice, or immediately where the breach is serious or cannot be cured. If we terminate for our own convenience, we refund the unused portion of the period paid.

6.6. Your data after termination. You can export your content from your account before or within 30 days after termination. We then delete it as described in the Privacy Policy.

Article 7 – Your obligations

7.1. Provide accurate information and keep it up to date.

7.2. Keep your sign-in credentials confidential and tell us promptly about any unauthorised use.

7.3. Use the Service in line with this Agreement, the Terms of Service, the policies of any social-media platform you connect, and the law. You are responsible for the content you generate, edit and publish, including for reviewing AI-generated output before publication and for any legally required labelling of AI-generated content.

7.4. Do not attempt to gain unauthorised access to the Service, interfere with its operation, resell it, or use it to infringe the rights of others.

Article 8 – Our obligations and your statutory remedies

8.1. We provide the Service as described on the order page and in the plan description, with reasonable skill and care, and we keep it in conformity throughout the subscription period, including by supplying the updates, including security updates, needed to keep it working.

8.2. If the Service does not conform, you may require us to bring it into conformity within a reasonable time. If we cannot, or do not, you may require a proportionate price reduction or terminate the Agreement and receive a refund for the non-conforming period. These are your rights under Law 6502 and, for EEA and UK consumers, under Directive (EU) 2019/770 and the Consumer Rights Act 2015 respectively. Nothing in this Agreement removes them.

8.3. Events outside our control. We are not in breach where performance is prevented by events beyond our reasonable control, such as natural disaster, epidemic, war, strikes, failures of public infrastructure or of third-party platforms and providers, or large-scale cyber-attack. Our obligations are suspended for the duration of the event and we will do what is reasonable to restore the Service. If such an event makes the Service substantially unavailable for more than 14 consecutive days, either party may terminate and you receive a pro-rata refund for the unused period. Your statutory rights are not otherwise affected.

8.4. We process your personal data in accordance with the Turkish Personal Data Protection Law No. 6698 and, where applicable, the GDPR and UK GDPR, as set out in our Privacy Policy.

Article 9 – Liability

9.1. Nothing in this Agreement limits our liability for death or personal injury caused by our negligence, for fraud, for gross negligence or wilful misconduct, or for anything that cannot be limited under the mandatory law of your country of residence.

9.2. Subject to 9.1, we are liable for foreseeable loss caused by our breach. We are not liable for loss of profit, business or goodwill arising from your professional use of the Service; if you use the Service for business purposes you are not a consumer and the Terms of Service apply instead.

9.3. AI-generated output may contain errors. We do not warrant its accuracy, originality or fitness for any specific purpose; you review it before relying on it or publishing it.

Article 10 – Complaints and dispute resolution

10.1. Please raise any complaint first with [email protected]. We aim to respond within 5 business days.

10.2. Consumers resident in Türkiye. For disputes with a value below the monetary limit set annually by the Ministry of Trade, which is TRY 186,000 for 2026, you may apply to the Consumer Arbitration Committee in your place of residence or in Bursa. For disputes above that limit you may apply to the Consumer Court; in that case an application to a mediator is a mandatory first step before filing a lawsuit, under Law 6502 Article 73/A. Applications can be made in person, by post, or online through e-Devlet.

10.3. Consumers resident in the EEA or UK. You may bring proceedings in the courts of your own country of residence, and nothing in this Agreement deprives you of the protection of the mandatory consumer law of that country, under Article 6 of Regulation (EC) 593/2008. We are not obliged to, and do not, participate in alternative dispute resolution schemes under Directive 2013/11/EU, but we will consider any proposal in good faith. The EU Online Dispute Resolution platform was discontinued in July 2025.

10.4. Subject to 10.2 and 10.3, this Agreement is governed by the laws of the Republic of Türkiye.

Article 11 – Entry into force and acceptance

11.1. This Agreement enters into force when you confirm your order electronically.

11.2. By confirming your order you declare that you have read this Agreement and the pre-contractual information on the order page, that you understood them, and that you accept them. You have separately confirmed, by unticked boxes, the recurring charge under Article 3.4 and the immediate-start request under Article 5, where applicable.

11.3. If any provision is invalid, the remainder stays in force. Where this Agreement and the Terms of Service conflict for a consumer, this Agreement prevails.

Article 12 – Business customers

If you are not a consumer, Article 5, Articles 6.4(a) and 6.4(b), and Articles 8.2, 9.2, 10.2 and 10.3 do not apply to you. Your subscription is governed by the Astramio Terms of Service and, where you upload personal data of others, the Data Processing Addendum. Disputes with business customers are subject to Turkish law and the exclusive jurisdiction of the Bursa courts and enforcement offices, after mandatory commercial mediation.

Annex – Model withdrawal form

Complete and return this form only if you wish to withdraw from the Agreement.

To: Astramio Bilişim Teknolojileri Sanayi ve Ticaret A.Ş., Görükle Mah. Üniversite-1 Cad. ULUTEK Teknoloji Geliştirme Bölgesi No:933, 16285 Nilüfer / Bursa, Türkiye, [email protected]

I hereby give notice that I withdraw from my contract for the following service: Astramio subscription, plan: ______
Ordered on: ______
Name of consumer: ______
Address of consumer: ______
Account email: ______
Signature (only if this form is sent on paper): ______
Date: ______

Last Updated: 05/09/2026