Terms and Conditions of Use of the VrapOn Taxi Platform

Effective as of 01.03.2023
Last updated 06.08.2026

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

1.1. These Terms and Conditions ("the Terms") govern the legal relationship between Upfront Albania sh.p.k., operator of the VrapOn Taxi digital platform ("VrapOn", "the Platform", "the Company"), and any natural or legal person who uses the mobile application, official website, or services provided through the Platform ("the User", "the Passenger", "the Client").

1.2. By creating an account, logging in, or using the Platform, the User declares that they: have read these Terms; fully understand them; accept them without reservation; commit to complying with them throughout their use of the Platform.

1.3. If the User does not agree with these Terms, they must not create an account or use the Platform.

Article 2 — Identity of the Platform

2.1. VrapOn is a technology platform that enables connection between: passengers; licensed taxi operators; licensed individual drivers.

2.2. VrapOn is not a transport company.

2.3. VrapOn does not own taxi vehicles.

2.4. VrapOn does not employ the drivers who provide transport through the Platform, except where expressly provided for in specific agreements.

2.5. Every transport service is carried out by operators licensed under Albanian legislation.

2.6. The transport agreement is concluded between the passenger and the licensed operator, while VrapOn acts as a technological intermediary.

Article 3 — Definitions

For the purposes of these Terms:

Platform means the VrapOn Taxi App, the official website, and any other electronic system administered by VrapOn.
Passenger is any user who books a trip.
Driver is the person authorized by a taxi operator to provide transport.
Taxi Operator is the legal entity or natural person licensed under Albanian legislation.
Booking is the request made by the Passenger for a trip to be carried out.
Trip is the transport carried out from the pick-up point to the destination.
Payment is any amount paid through the Platform or directly to the driver.
Payment Card means Visa, Mastercard, or other electronic intermediary instruments accepted by the Platform and applicable Albanian legislation for online payments.
Fare is the price of the trip or any additional charge under these Terms.

Article 4 — Scope of Application

4.1. These Terms apply to: the VrapOn Taxi Albania application; the website www.vrapon.al; online bookings; electronic payments; cash payments; Business services; any new module that may be added in the future.

4.2. If the Platform adds new services (such as car rentals, shuttle, hotel or restaurant bookings, plane, bus, or ferry tickets, or other services), these Terms will also apply to them, unless separate terms are published.

Article 5 — Electronic Acceptance

5.1. Clicking the "I Accept the Terms and Conditions" button has the same legal force as a physical signature.

5.2. The User accepts that electronic documents have full legal validity under Albanian legislation.

Article 6 — Changes to the Terms

6.1. VrapOn reserves the right to change these Terms at any time.

6.2. The most recent version is published on the official website and in the application.

6.3. Continued use of the Platform after changes take effect is considered acceptance of them.

Article 7 — Conditions for Using the Platform

The User declares that they:

• are at least 18 years old or have full legal capacity;
• provide accurate information;
• will not use a false identity;
• will not create multiple accounts for fraudulent purposes;
• will not compromise the security of the system;
• will not use the Platform for unlawful activities.

Article 8 — Order of Precedence of Documents

In the event of a discrepancy between: these Terms; the Privacy Policy; the Payment Policy; the Refund Policy — the documents will apply in the order set by VrapOn, unless the law provides otherwise.

CHAPTER II — USER ACCOUNT, VERIFICATION AND SECURITY

Article 9 — Creating an Account

9.1. To use the Platform's services, the User must create a personal account ("the Account").

9.2. The Account may be created through: the VrapOn Taxi application; the official website, if this functionality is offered; other platforms authorized by VrapOn.

9.3. During registration, the User must provide accurate, complete, and up-to-date information, including, as applicable: name; phone number; email address; payment method details, if electronic payment is selected; any other information required for the Platform to function.

9.4. VrapOn reserves the right to request additional information or verification documents where necessary for the security of the Platform, compliance with legal obligations, or fraud prevention.

Article 10 — Conditions for Creating an Account

10.1. The User declares and warrants that: they have full legal capacity to enter into this agreement; the information provided is true; they will not create an account on behalf of another person without authorization; they will not use a false identity.

10.2. VrapOn may refuse to create an account if there is reasonable ground to suspect that the information provided is inaccurate, fraudulent, or unlawful.

Article 11 — Identity Verification

11.1. For security and legal compliance reasons, VrapOn may require verification of the User's identity.

11.2. The verification process may include: verifying the phone number via an OTP code; verifying the email address; verifying an identity document, when necessary; verifying the payment card or payment method; other reasonable checks to prevent fraud.

11.3. If the User refuses to complete the verification process, VrapOn may restrict or suspend access to some or all of the Platform's functionalities.

Article 12 — Account Security

12.1. The User is responsible for maintaining the confidentiality of their account credentials.

12.2. The User must not: share OTP codes with third parties; allow other persons to use their account; use an account that does not belong to them.

12.3. Any action carried out through the account is considered to have been carried out by the User themselves, except where they immediately notify VrapOn of unauthorized use.

12.4. In case of suspected account compromise, the User must: immediately change their password (if used); contact VrapOn's support team; cooperate during the verification process.

Article 13 — Personal Use of the Account

13.1. The Account is personal and may not be sold, transferred, rented, or used by another person.

13.2. VrapOn is not liable for damages arising from unauthorized use of the account due to the User's negligence.

Article 14 — Payment Methods

14.1. The User may register one or more payment methods on the Platform.

14.2. The User warrants that: they are the lawful owner of the card or are authorized to use it; the card information is accurate; the card is valid.

14.3. VrapOn does not store full bank card details. Payments are processed by licensed payment service providers in accordance with international security standards, through the Platform's integrated partners.

14.4. If a payment is declined, VrapOn may request an alternative payment method or restrict the use of services until the obligation is settled.

Article 15 — Prohibited Activities

The User is not permitted to: create multiple accounts to benefit from offers or promotions; use stolen or unauthorized payment cards; make fake bookings; use applications or tools to manipulate the Platform; compromise the security of VrapOn's systems; interfere with the normal operation of the application; use the Platform for unlawful activities.

Article 16 — Fraud and Suspicious Activity

16.1. VrapOn uses technical mechanisms and procedures to identify: suspicious transactions; unauthorized use of cards; fraudulent bookings; promo code abuse; mass account creation; manipulation of the rating system.

16.2. In case of reasonable suspicion of fraud, VrapOn may: temporarily suspend the account; block payments or refunds until verification is complete; request additional documentation; refuse transactions; permanently close the account; notify the competent authorities, when required by law.

Article 17 — Suspension and Closure of the Account

17.1. VrapOn may suspend or close the User's account in cases where the User: violates these Terms; uses fraudulent payment methods; threatens or assaults drivers, employees, or other users; damages vehicles; carries out unlawful acts; poses a risk to the security of the Platform.

17.2. In case of suspension or closure, VrapOn may cancel active bookings and restrict access to services.

17.3. Closing the account does not release the User from the obligation to pay outstanding fares or amounts owed.

Article 18 — Deleting the Account

18.1. The User may request deletion of their account at any time, through the application or by contacting support.

18.2. VrapOn may retain certain data even after the account is deleted, where required by applicable law or necessary for: fraud protection; dispute resolution; compliance with tax or legal obligations; the exercise or defense of the Company's legal rights.

18.3. Deletion of the account does not affect obligations arising prior to the date of deletion.

CHAPTER III — BOOKING TRIPS AND PROVISION OF THE SERVICE

Article 19 — Nature of the Service

19.1. VrapOn is a technology platform that enables the intermediation of transport requests between Passengers and licensed Taxi Operators.

19.2. VrapOn is not a direct provider of transport services, does not own taxi vehicles, and does not guarantee the continuous availability of a Driver.

19.3. The transport service is carried out by the Taxi Operator through the authorized Driver, who bears responsibility for carrying out the trip in accordance with applicable legislation.

19.4. The contractual relationship for transport is created between the Passenger and the Taxi Operator, while VrapOn provides only the technological intermediation service.

Article 20 — Trip Request

20.1. The Passenger may submit a trip request through the Platform by specifying: the pick-up location; the destination; the type of service (if different categories are offered); the payment method; any other necessary information.

20.2. Submitting a request does not automatically guarantee its acceptance by a Driver.

20.3. A request is considered accepted only once a Driver confirms it on the Platform.

Article 21 — Driver Availability

21.1. Driver availability depends on: location; time of day; market demand; weather conditions; traffic; other factors beyond VrapOn's control.

21.2. VrapOn does not guarantee that every trip request will be accepted.

21.3. In the absence of available Drivers, a request may be automatically declined or cancelled.

Article 22 — Information About the Driver

Once a request is accepted, the Platform may display to the Passenger: the Driver's name; photo (if available); vehicle make and model; license plate; the Driver's average rating; estimated arrival time. This information is provided solely for the purpose of carrying out the trip and may not be used for other purposes.

Article 23 — Driver's Arrival

23.1. The Passenger must be at the pick-up point at the scheduled time.

23.2. The Driver is entitled to wait for a reasonable period of time, in accordance with VrapOn's operating policies.

23.3. If the Passenger does not show up within the waiting period: the Driver may cancel the trip; a "No Show" fee may apply; the trip is considered cancelled by the Passenger.

Article 24 — Passenger Verification

The Driver has the right to confirm the Passenger's identity through: name; destination; trip code, if this functionality is offered by the Platform. This procedure aims to prevent the wrong person from boarding.

Article 25 — During the Trip

The Passenger is obliged to: treat the Driver with respect; not interfere with the driving of the vehicle; wear a seatbelt when required; not consume prohibited substances; not damage the vehicle; not obstruct the normal course of the trip.

Article 26 — Change of Destination

26.1. The Passenger may request a change of destination during the trip.

26.2. The Driver may accept or decline this request if it: creates a risk; conflicts with legislation; makes it impossible to complete the trip.

26.3. A change of destination may affect the final fare.

Article 27 — Stops During the Trip

27.1. The Platform may allow the addition of one or more stops.

27.2. Waiting time during stops may be charged according to applicable rates.

27.3. The Driver is not obliged to wait beyond the maximum time set by VrapOn's operating policies.

Article 28 — Refusal of the Trip

The Driver may refuse to start or continue a trip if: the Passenger poses a safety risk; is under the influence of alcohol or narcotic substances to a degree that compromises safety; attempts to transport prohibited items; attempts to transport dangerous goods; engages in physical or verbal violence; refuses to comply with the law or these Terms. In such cases, VrapOn is not liable for the trip not being carried out.

Article 29 — Transport of Children

29.1. The Passenger is responsible for complying with legal requirements regarding the transport of minors.

29.2. If the law requires the use of a child seat, providing it is the Passenger's responsibility, except where the Platform offers a dedicated service.

29.3. The Driver may refuse the trip if the legal conditions for transporting children are not met.

Article 30 — Luggage

30.1. The Passenger should declare, in advance where possible, any unusual or oversized luggage.

30.2. The Driver may refuse to transport luggage that: does not fit in the vehicle; poses a safety risk; is prohibited by law; may cause damage.

30.3. VrapOn does not guarantee the availability of vehicles with special luggage capacity.

Article 31 — Pets

31.1. Transport of pets is permitted only if: legal requirements are met; the animal does not pose a risk; the Driver accepts the transport.

31.2. Pets must be transported safely and hygienically.

31.3. In case of damage to or soiling of the vehicle, the Passenger may be liable for the related costs.

Article 32 — Vehicle Damage

32.1. The Passenger is liable for any damage caused to the vehicle intentionally or through negligence.

32.2. VrapOn may facilitate communication between the Taxi Operator and the Passenger to resolve claims, without assuming liability for the damage itself.

Article 33 — End of the Trip

33.1. The trip is considered completed when the Driver marks it as such on the Platform or when the Passenger exits at the destination.

33.2. After the trip is completed, the Platform may issue an electronic invoice or confirmation containing the basic information about the trip and payment.

Article 34 — Ratings

34.1. The Passenger and Driver may rate each other after completing the trip.

34.2. Ratings must be honest, objective, and must not contain offensive, discriminatory, or defamatory language.

34.3. VrapOn reserves the right to remove or refrain from publishing comments that violate these Terms or applicable legislation.

CHAPTER IV — PRICES, FARES, PAYMENTS AND REFUNDS

Article 35 — Determination of the Trip Price

35.1. The price of a trip is determined in accordance with VrapOn's pricing policies (rates approved by each city's Municipal Council) and may be based on one or more of the following elements: base fare; distance travelled; trip duration; waiting time; fixed fare for certain routes; dynamic fare, where applicable; additional charges provided for in these Terms. All of the above are subject to applicable legal provisions on transport and taxi transport.

35.2. The Platform may present the Passenger with an estimated price before the booking is confirmed. This price is informational, except where expressly specified as a fixed fare.

35.3. The final price may change if: the destination changes during the trip; stops are added; a waiting fee applies; the trip deviates at the Passenger's request; extraordinary events affecting the route occur.

Article 36 — Fixed Fares

36.1. For certain routes, VrapOn may offer fixed fares, where the actual metered value of the trip is covered by the company.

36.2. The fixed fare remains unchanged, except where: the Passenger changes the destination; stops are added; the route is significantly changed at the Passenger's request.

36.3. Deviations caused by traffic, roadworks, or other circumstances beyond the Driver's control do not automatically affect the fixed fare, unless VrapOn's pricing policies provide otherwise.

Article 37 — Dynamic Fares

37.1. During periods of high demand or limited Driver availability, VrapOn may apply dynamic fares.

37.2. Any dynamic fare will be shown to the Passenger before the booking is confirmed.

37.3. By confirming the booking, the Passenger accepts the displayed fare.

Article 38 — Payment Methods

38.1. The Platform may support one or more of the following payment methods: cash; debit card; credit card; electronic wallet (if offered); other methods authorized by VrapOn.

38.2. VrapOn reserves the right to add, restrict, or remove payment methods at any time.

Article 39 — Card Payments

39.1. By registering a payment card on the Platform, the User authorizes VrapOn or the payment service provider to charge the card for: the trip fare; the cancellation fee; the "No Show" fee; other charges provided for in these Terms.

39.2. Certain charges may be carried out as a pre-authorization to verify the validity of the card. The pre-authorized amount does not constitute a final payment and is released according to the issuing bank's procedures.

39.3. If a payment is declined, VrapOn may request an alternative payment method or restrict access to services until the obligation is settled.

Article 40 — Electronic Invoices

40.1. After the trip is completed, the Platform may issue an electronic invoice or confirmation containing: the date and time of the trip; the pick-up point and destination; the fare paid; the payment method; any additional charges applied.

40.2. The electronic invoice/confirmation serves as proof of the transaction, without replacing fiscal documents issued under applicable legislation.

Article 41 — Refund Policy

41.1. VrapOn reviews refund requests individually, taking into account the specific circumstances of each case.

41.2. A refund may be approved, among other cases, where: a duplicate payment has been made for the same trip; an unauthorized payment has been made; a technical error of the Platform has been identified; an incorrect fare has been applied due to a system defect; the trip was not carried out for reasons directly attributable to the Platform.

41.3. VrapOn may request documentation or additional information to verify the refund request.

41.4. Approval of a refund does not create a precedent and does not guarantee approval of similar requests in the future.

Article 42 — Cases Where No Refund Is Given

A refund will not be given, among other cases, when: the trip was carried out as booked; the Passenger changed their mind after the trip was completed; the trip was cancelled outside the permitted period; a "No Show" fee was correctly applied; the price change resulted from a change of destination or added stops; the delay was caused by traffic, weather, or other factors beyond VrapOn's control.

Article 43 — Deadline for Refund Requests

43.1. Refund requests must be submitted within 30 (thirty) calendar days from the date of the transaction, unless applicable legislation provides for a longer period.

43.2. Requests submitted after this deadline may be refused.

Article 44 — Method and Timing of Refunds

44.1. If a request is approved, the refund is issued, as applicable: to the same payment card; via the same payment method originally used; or through another method agreed with the User, where possible.

44.2. VrapOn will process and initiate the transfer of the approved amount within 3-5 (three to five) business days from the date the request is approved. The time it takes for the amount to reflect in the User's bank account after the transfer is initiated depends on the procedures of the bank or payment service provider and is outside VrapOn's control.

Article 45 — Chargebacks

45.1. If the User initiates a chargeback procedure with their bank or card issuer, VrapOn has the right to submit relevant documentation to defend the validity of the transaction.

45.2. If a chargeback is found to be unfounded or abusive, VrapOn may: require settlement of the obligation; suspend the account; restrict use of the Platform; take necessary legal action.

Article 46 — Financial Fraud

46.1. VrapOn reserves the right to suspend or refuse transactions considered suspicious.

46.2. For security purposes, VrapOn may cooperate with: financial institutions; payment providers; competent authorities.

46.3. VrapOn may request additional documentation to verify the identity or validity of a transaction.

Article 47 — Responsibility for Payments

47.1. The User is responsible for ensuring that the chosen payment method is valid and has sufficient funds.

47.2. VrapOn is not liable for: a transaction being declined by the bank; restrictions imposed by the card issuer; delays in payment processing by payment service providers; disruptions of banking systems or payment networks.

Article 48 — Correction of Errors

48.1. If VrapOn identifies a billing error, it may correct the transaction by: refunding the excess amount; charging the remaining amount, if the correct fare was not fully collected, in accordance with the law and with appropriate notice.

48.2. The User has the right to dispute any correction within the period set by VrapOn or by applicable legislation.

CHAPTER V — CANCELLATIONS, "NO SHOW" FEES, USER CONDUCT AND LOST ITEMS

Article 49 — Right to Cancel

49.1. The Passenger has the right to cancel a trip request at any time before it is completed, in accordance with these Terms and VrapOn's operating policies.

49.2. The Driver has the right to cancel a request only for reasonable grounds, including but not limited to: inability to locate the Passenger; safety risk; inappropriate conduct by the Passenger; a technical or mechanical problem with the vehicle; unforeseen circumstances preventing the trip from being carried out.

49.3. VrapOn may cancel a booking if necessary for reasons of safety, fraud, force majeure, or breach of these Terms.

Article 50 — Cancellation Fee

50.1. If the Passenger cancels the booking after the Driver has accepted the request or has set off toward the pick-up point, a cancellation fee may apply.

50.2. The cancellation fee is intended to compensate the Taxi Operator and Driver for their time and costs.

50.3. The amount of the fee is determined according to VrapOn's pricing policies and may vary depending on: the time of cancellation; the distance travelled by the Driver; the waiting time; the service category.

50.4. The cancellation fee is communicated to the Passenger transparently before the booking is confirmed or within the application.

Article 51 — "No Show" Fee

51.1. If the Driver arrives at the pick-up point and the Passenger does not show up within the waiting period set by VrapOn, the Driver may cancel the trip.

51.2. In this case, VrapOn may apply a "No Show" fee.

51.3. The "No Show" fee does not constitute a penalty but compensates the Driver's time and expenses.

51.4. The "No Show" fee is not refundable, except where a Platform error or documented extraordinary circumstances are proven.

Article 52 — Driver No-Show

52.1. If the Driver does not arrive at the pick-up point within a reasonable time, or cancels without justified reason, the Passenger will not be charged.

52.2. In cases of repeated Driver no-shows, VrapOn may take administrative measures against the Taxi Operator or Driver, in accordance with the relevant agreements.

Article 53 — Passenger Conduct

53.1. The Passenger is obliged to behave respectfully toward the Driver and other users.

53.2. The following are prohibited: offensive or threatening language; any form of discrimination; verbal or physical harassment; damaging the vehicle; deliberately soiling the vehicle; consuming prohibited substances; transporting items prohibited by law.

53.3. The above violations may lead to suspension or closure of the Passenger's account and, where necessary, notification of the competent authorities.

Article 54 — Driver Conduct

54.1. The Driver must: treat Passengers with respect and professionalism; comply with road traffic rules; use a licensed vehicle in good technical condition; not discriminate against Passengers; not request payments outside the Platform's fares, except where expressly permitted.

54.2. VrapOn may take measures against Drivers who violate these standards, in accordance with the cooperation agreements.

Article 55 — Vehicle Damage or Soiling

55.1. If the Passenger causes significant damage to or soiling of the vehicle, they may be liable for the reasonable costs of repair or cleaning.

55.2. The Taxi Operator must provide sufficient evidence of the claimed damage, such as photographs, documentation, or invoices.

55.3. VrapOn may facilitate communication between the parties but is not a party to the compensation relationship and does not guarantee payment of claims.

Article 56 — Lost Items

56.1. The Passenger is responsible for checking their personal belongings before leaving the vehicle.

56.2. If an item is left in the vehicle, the Passenger should contact VrapOn as soon as possible.

56.3. VrapOn will attempt to facilitate contact with the Driver or Taxi Operator but does not guarantee: finding the item; its safekeeping; its return.

56.4. Responsibility for lost items rests with the item's owner and, as applicable, the Taxi Operator, in accordance with applicable legislation.

Article 57 — Transport of Valuables

57.1. Passengers are advised not to leave valuables unattended, including: cash; jewelry; electronic devices; identification documents; passports; bank cards.

57.2. VrapOn is not liable for the loss, damage, or theft of such items.

Article 58 — Ratings and Comments

58.1. After the trip is completed, the Passenger and Driver may give ratings and comments.

58.2. Ratings must be: accurate; objective; based on actual experience.

58.3. Publication of comments that are: offensive; defamatory; contain hate speech; disclose personal data of other parties, is prohibited.

58.4. VrapOn reserves the right to moderate or remove comments that violate these Terms or applicable legislation.

Article 59 — Reporting Issues

59.1. Any claim relating to a trip must be submitted through VrapOn's official support channels.

59.2. The User must provide complete and accurate information to facilitate review of the request.

59.3. VrapOn will review the claim within a reasonable period and will notify the User of the outcome.

Article 60 — Communication Between Parties

60.1. Communication between the Passenger and Driver must be limited to matters related to carrying out the trip.

60.2. Use of contact details obtained through the Platform is prohibited for: unauthorized marketing; harassment; communications unrelated to the trip; any other purpose unrelated to the service.

60.3. VrapOn may monitor or record communications carried out through the Platform's features (e.g. in-app calls or messages between the Passenger and the Driver), when necessary for safety, service quality, complaint investigation, or compliance with legal obligations. The User is notified of this possibility at the time of account creation and before the start of any in-app call or conversation, through a clear notice in the interface. Recordings are retained for a maximum period of 90 (ninety) days, except where a longer period is required for the investigation of a complaint, fraud, or an ongoing legal proceeding, and are processed in accordance with Articles 75-76 of these Terms.

CHAPTER VI — LIMITATION OF LIABILITY AND THIRD-PARTY SERVICES

Article 61 — VrapOn's Role

61.1. VrapOn is a technology platform that enables connection between Passengers and licensed Taxi Operators.

61.2. VrapOn is not a transport operator, does not directly provide the transport service, and is not the employer of Drivers, except where expressly provided for by a specific agreement.

61.3. Responsibility for carrying out the trip, safety during transport, and compliance with public transport legislation lies with the Taxi Operator and Driver.

61.4. VrapOn does not guarantee that every trip request will be accepted or that a Driver will always be available.

Article 62 — Limitation of Liability

62.1. To the extent permitted by applicable legislation, VrapOn is not liable for damages or losses arising from: delays in Driver arrival; heavy traffic; road accidents; roadworks; weather conditions; natural disasters; road blockages; demonstrations, protests, or other public events; disruptions to communication networks; GPS system malfunctions; internet outages; defects in the User's equipment; disruptions to payment systems.

62.2. VrapOn does not guarantee that the Platform will be available at all times or without interruption.

Article 63 — Missed Flights and Bookings

63.1. The Passenger is responsible for planning their trip taking into account traffic, weather conditions, and other unforeseeable factors.

63.2. VrapOn is not liable for missing or delays to: flights; trains; buses; ferries; hotel bookings; restaurant bookings; work meetings; job interviews; other activities or events.

63.3. Even where the Platform displays an estimated arrival time, this time is indicative only and does not constitute a contractual guarantee.

Article 64 — Third-Party Services

64.1. VrapOn may offer or integrate, now or in the future, access to services provided by third parties, including but not limited to: hotels; restaurants; plane tickets; bus tickets; ferry tickets; car rentals; shuttle; tourist services; delivery services; other electronic payments.

64.2. In these cases, VrapOn acts only as a technological intermediary and is not the provider of these services.

64.3. The contractual relationship is created directly between the User and the relevant service provider.

64.4. Any claim regarding the quality, cancellation, refund, delay, or non-performance of these services must be addressed to the relevant provider.

Article 65 — Payments for Third-Party Services

65.1. If the Platform facilitates payment for third-party services, this does not mean that VrapOn is the seller or provider of that service.

65.2. VrapOn is not liable for: refusal of the booking by the third party; cancellation of the booking; price changes by the provider; the quality of the service; failure of the provider to issue a refund; any dispute between the User and the service provider.

Article 66 — Quality of the Transport Service

66.1. VrapOn cooperates only with licensed Taxi Operators.

66.2. However, VrapOn does not guarantee the individual quality of every trip, as the service is provided by independent Operators.

66.3. Any claim regarding the Driver's conduct or the vehicle's condition will be reviewed by VrapOn and, as applicable, referred to the relevant Operator or competent authorities.

Article 67 — Indirect Damages

67.1. To the extent permitted by law, VrapOn is not liable for: loss of profit; loss of business; loss of revenue; loss of business opportunities; reputational damage; moral damages, except where otherwise provided by law; indirect or consequential damages.

Article 68 — Force Majeure

68.1. VrapOn is not liable for failure or delay in providing the Platform where this is caused by circumstances beyond the Company's reasonable control, including: earthquakes; floods; fires; pandemics; epidemics; war; acts of terrorism; embargoes; strikes; large-scale power outages; large-scale cyberattacks; decisions of public authorities.

68.2. For the duration of a force majeure event, VrapOn's obligations are suspended for as long as the obstacle persists.

Article 69 — Maximum Limitation of Liability

69.1. To the extent permitted by law, VrapOn's total liability to a User for any claim related to a trip or the use of the Platform shall not exceed the amount of the fare paid for that trip, unless applicable legislation provides otherwise.

69.2. The limitation set out in Article 69.1 does NOT apply, and does not limit or exclude VrapOn's liability, in cases of: (a) death or bodily injury caused by VrapOn's negligence; (b) intentional misconduct (dolus) or gross negligence (culpa lata) on the part of VrapOn; (c) any type of liability that, under applicable Albanian legislation, cannot be limited or excluded by agreement. Nothing in these Terms limits or excludes VrapOn's liability in cases where such a limitation is prohibited by law.

Article 70 — Indemnification

70.1. The User agrees to indemnify and hold harmless VrapOn, its administrators, employees, and partners from any claim, loss, cost, or liability arising from: breach of these Terms; unlawful use of the Platform; infringement of third-party rights; unauthorized use of payment methods; fraudulent or unlawful acts by the User.

70.2. This provision applies to the extent permitted by Albanian legislation.

CHAPTER VII — INTELLECTUAL PROPERTY, DATA PROTECTION, APPLICABLE LAW AND FINAL PROVISIONS

Article 71 — Intellectual Property

71.1. The VrapOn Taxi Platform, mobile application, official website, logo, VrapOn trade name, graphic interface, design, database, source code, object code, algorithms, technical documentation, texts, graphics, icons, photographs, videos, audio materials, trademarks, and any other element of the Platform are the exclusive property of Upfront Albania sh.p.k.

71.2. No provision of these Terms transfers to the User any intellectual property right over the Platform or its elements.

71.3. The User is granted only a personal, limited, non-exclusive, non-transferable, and revocable license to use the Platform in accordance with these Terms.

Article 72 — License Restrictions

The User is not permitted to: copy the application; modify the Platform; decompile or reverse engineer it; create derivative applications; sell or rent out the Platform; use bots or automated systems for data extraction (scraping); use the Platform's APIs without authorization; compromise its technical security measures. Any use outside this license is considered a violation of intellectual property rights.

Article 73 — Trademark

73.1. The VrapOn name, logo, and any other mark registered or used by the Company are protected under industrial property legislation.

73.2. Their use without VrapOn's prior written approval is prohibited.

Article 74 — User-Generated Content

74.1. Users may publish comments, ratings, or other content on the Platform.

74.2. By publishing such content, the User grants VrapOn a non-exclusive, royalty-free, worldwide, revocable license to use it solely for: the operation of the Platform; improving services; moderation; handling complaints.

74.3. The User warrants that the content published does not infringe third-party rights and does not contain unlawful material.

Article 74A — Right of Withdrawal

74A.1. Transport services provided through the Platform are excluded from the general 14-day right of withdrawal applicable to distance contracts, as the provision of the service is tied to a specified time or date and is carried out immediately or within a short period after booking, in accordance with the exemptions provided under Albanian consumer protection legislation for passenger transport services.

74A.2. This provision does not affect the User's other rights under the Refund Policy (Annex 3) in cases of a trip not being carried out, technical errors, or incorrect charges.

Article 75 — Protection of Personal Data

75.1. VrapOn processes personal data in accordance with Albanian personal data protection legislation and, where applicable, the standards of the General Data Protection Regulation (GDPR).

75.2. Data is processed only for lawful purposes and on the following legal bases:

• account creation and administration — based on performance of the contract with the User;
• carrying out bookings and trips — based on performance of the contract;
• payment processing — based on performance of the contract and compliance with legal (tax, accounting) obligations;
• customer support — based on VrapOn's legitimate interest and performance of the contract;
• fraud prevention and Platform security — based on VrapOn's legitimate interest;
• compliance with legal obligations (tax, accounting, reporting to authorities) — based on legal obligation;
• marketing and promotional communications — based on the User's consent, where required;
• service quality improvement and statistical analysis — based on VrapOn's legitimate interest.

75.3. Data retention periods:

• account data and trip history are retained for as long as the account is active and for up to 5 (five) years after its closure, for tax, accounting, and legal defense purposes, in accordance with the statute-of-limitations periods under Albanian legislation;
• financial transaction data and invoices are retained for the period required under applicable Albanian tax legislation;
• communication recordings (Article 60.3) are retained for up to 90 days, except where a longer period is needed for an investigation or legal proceeding;
• other data that is no longer necessary for the purposes for which it was collected is deleted or anonymized, except where the law requires longer retention.

75.4. Data location and transfer: Users' personal data is stored and processed on Google Cloud infrastructure, in data centers located in Germany, within the European Union. For the transfer of data from Albania to the European Union, VrapOn applies appropriate safeguards (including standard contractual clauses and/or reliance on an adequate level of protection), in accordance with Albanian personal data protection legislation.

75.5. Data protection contact (DPO / Privacy Officer): Users may contact VrapOn for any matter relating to personal data protection, the exercise of rights under Article 76, or the reporting of a possible breach, at the phone number: +355 67 201 9470.

Article 76 — User Rights Regarding Personal Data

The User has the right to request: access to their personal data; correction of inaccurate data; deletion of data, where permitted by law; restriction of processing; data portability; objection to processing in the cases provided for by law. Requests may be submitted through VrapOn's official communication channels or at the contact provided in Article 75.5.

Article 77 — Cookies and Similar Technologies

77.1. The Platform and official website may use cookies and similar technologies for: technical operation; storing preferences; statistical analysis; performance improvement; Platform security.

77.2. Detailed information is provided in the Cookie Policy (Annex 1).

Article 78 — Electronic Communications

78.1. By using the Platform, the User agrees to receive electronic communications from VrapOn, including: booking confirmations; electronic invoices; security notices; changes to the Terms; communications related to the operation of the Platform.

78.2. Promotional communications are sent only in accordance with the User's preferences and applicable legislation.

Article 79 — Applicable Law

79.1. These Terms are governed by and interpreted in accordance with the laws of the Republic of Albania.

79.2. If a provision of these Terms conflicts with a mandatory rule of law, the legal rule applies and the other provisions remain in force.

Article 80 — Dispute Resolution

80.1. The parties will first attempt to resolve any dispute amicably.

80.2. The User may submit a complaint through VrapOn's official channels.

80.3. VrapOn will review the complaint and provide a response within a reasonable period.

80.4. If the dispute is not resolved amicably, it shall be subject to the jurisdiction of the competent courts of the Republic of Albania, unless the law provides otherwise.

Article 81 — Partial Invalidity

81.1. If a provision of these Terms is declared invalid or unenforceable by a competent authority, the remaining provisions remain in force.

81.2. The invalid provision will be replaced, where possible, with a provision that most closely approximates its economic and legal purpose.

Article 82 — Transfer of Rights

82.1. VrapOn may transfer the rights and obligations arising from these Terms in the context of a reorganization, merger, sale, or business transfer, in accordance with the law.

82.2. The User may not transfer their rights or obligations without VrapOn's prior written approval.

Article 83 — Changes to the Terms

83.1. VrapOn reserves the right to change these Terms at any time.

83.2. The updated version is published on the official website and, where appropriate, also announced in the application.

83.3. Continued use of the Platform after changes take effect is considered acceptance of them.

Article 84 — Entry Into Force

84.1. These Terms take effect on the date they are published on VrapOn's official website, or on another date expressly set by the Company.

84.2. These Terms replace any previous version of the VrapOn Platform Terms and Conditions of Use.

ANNEX 1 — COOKIE POLICY

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

1.1. This Cookie Policy ("the Policy") explains how Upfront Albania sh.p.k. ("VrapOn", "the Company", "we") uses cookies and similar technologies when using: the VrapOn Taxi application; the official website www.vrapon.al; the VrapOn Business platform; any other electronic service provided by the Company.

1.2. The Policy aims to inform users about: the types of cookies used; the purposes of their use; the retention period; how they are managed; users' rights.

Article 2 — Definitions

Cookie — A small text file stored on the user's device during a visit to a website or use of a platform.
Session Cookie — A cookie that is automatically deleted when the user closes the browser or ends the session.
Persistent Cookie — A cookie stored on the device until its expiry date or until the user deletes it.
First Party Cookie — A cookie set by VrapOn.
Third Party Cookie — A cookie set by an external provider.

Article 3 — Scope of Application

This Policy applies to: the website www.vrapon.al; the VrapOn Business panel; promotional pages; online forms; web applications; any other platform administered by VrapOn. For mobile applications, equivalent technologies (SDK, Local Storage, Device Identifiers, etc.) are treated under the same principles.

Article 4 — Acceptance

By using the website or application, the user accepts the use of cookies under this Policy, to the extent required by law and their consent choices.

CHAPTER II — TYPES OF COOKIES

Article 5 — Essential Cookies

Essential cookies are necessary for the Platform to function. Without them, functions such as the following cannot be performed: account login; taxi booking; payments; session security; protection against cyberattacks; server load balancing. These cookies cannot be disabled while using the Platform.

Article 6 — Performance Cookies

VrapOn may use cookies to analyze the Platform's performance. These include: page load times; technical errors; usage statistics; server performance analysis. The purpose is to improve the quality of the service.

Article 7 — Analytics Cookies

Analytics cookies help understand how users use the Platform. Data that may be collected includes: most visited pages; time spent; clicks; navigation flow; device used; operating system; browser. This data is used in aggregate form and is not intended to directly identify the user.

Article 8 — Functionality Cookies

These cookies allow the Platform to remember the user's preferences. For example: language; currency; map preferences; notification preferences; saved locations; preferred payment method.

Article 9 — Marketing Cookies

With the user's consent, VrapOn may use marketing cookies for: personalized advertising; measuring campaign effectiveness; remarketing; conversion analysis. These cookies may be set by authorized partners.

CHAPTER III — SIMILAR TECHNOLOGIES

Article 10 — SDKs

In mobile applications, VrapOn may use Software Development Kits (SDKs) for: application operation; push notifications; performance analysis; error detection; security improvements.

Article 11 — Device Identifiers

The Platform may use unique device identifiers such as: Android Advertising ID; Apple Identifier for Advertisers (IDFA), where permitted; Firebase Installation ID; Device Token for push notifications.

Article 12 — Local Storage

The Platform may store local data for: user preferences; the active session; configurations; technical cache.

CHAPTER IV — THIRD-PARTY COOKIES

Article 13 — Partners

VrapOn may cooperate with external providers for analytics, performance, or communication purposes. These partners may use cookies or similar technologies in accordance with their own privacy policies. Current or future integrations may include: analytics services; map providers; notification delivery systems; payment providers; customer support platforms. VrapOn will update this Policy when the list of partners changes materially.

Article 14 — Responsibility

VrapOn does not control the privacy policies of third parties and recommends that users review the relevant documentation of these providers.

CHAPTER V — MANAGING COOKIES

Article 15 — Consent

15.1. Essential cookies (Article 5) are set automatically, as they are necessary for the Platform to function, and do not require prior consent.

15.2. Non-essential cookies (performance, analytics, non-essential functionality, marketing) are set ONLY after the User has given active (opt-in) consent through a dedicated cookie banner or management panel. These cookies are disabled by default (OFF) until the User expressly chooses to enable them.

15.3. The User may: accept all cookies; reject all non-essential cookies with a single click (just as easily as accepting them); select individual permitted categories.

15.4. Rejecting non-essential cookies does not restrict access to the Platform's core functions.

Article 16 — Changing Preferences

The User may change their cookie preferences at any time through: the cookie management panel on the official website, if offered; browser settings; device settings, where applicable. Disabling some cookies may limit certain features of the Platform.

Article 17 — Deleting Cookies

The User may delete cookies at any time through their browser or device settings. Deleting cookies may require logging into the account again or resetting some preferences.

CHAPTER VI — SECURITY AND RETENTION

Article 18 — Security

VrapOn implements technical and organizational measures to protect information related to cookies from unauthorized access, use, or disclosure.

Article 19 — Retention Period

Cookies are retained only for the period necessary for the purpose for which they were set. The duration may vary depending on the cookie category and legal requirements.

Article 20 — Updating the Policy

VrapOn reserves the right to change this Policy at any time to reflect: legal changes; technological developments; changes in services or partners. The most recent version will be published on the official website.

Article 21 — Contact

For any questions regarding this Policy or the use of cookies, users may contact VrapOn at the official contact address or the dedicated privacy number: +355 67 201 9470.

ANNEX 2 — PAYMENT POLICY

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

1.1. This Payment Policy ("the Policy") governs the manner in which payments are made for services provided through the VrapOn Taxi Platform.

1.2. The Policy applies to all users who make payments through the Platform, regardless of the payment method chosen.

1.3. This Policy is an integral part of the Terms and Conditions of Use and must be read together with the Privacy Policy and the Refund Policy.

Article 2 — Definitions

Platform — VrapOn's application and electronic systems.
Passenger — the user who books and pays for a trip.
Payment Service Provider (PSP) — the authorized institution that processes electronic payments on VrapOn's behalf.
Payment Card — a debit, credit, or prepaid card accepted by the Platform.
Authorization — the temporary reservation of funds on the user's card prior to final settlement.
Settlement — the final transfer of the payment amount.

CHAPTER II — PAYMENT METHODS

Article 3 — Accepted Methods

VrapOn may accept one or more of the following payment methods: cash; debit card; credit card; prepaid card; electronic wallet (if offered); Apple Pay (if supported); Google Pay (if supported); other methods approved by VrapOn. The list of available methods may change at any time.

Article 4 — Choosing a Payment Method

4.1. The Passenger chooses the payment method before or during the trip booking.

4.2. VrapOn may restrict certain payment methods for specific service categories or geographic areas.

4.3. If the chosen method fails, the Passenger may be required to use an alternative method.

CHAPTER III — CARD PAYMENTS

Article 5 — Card Registration

5.1. The User may register one or more payment cards on the Platform.

5.2. VrapOn does not store the full card number, CVV/CVC code, or other sensitive payment data. This is processed and stored by the authorized payment service provider, in accordance with applicable security standards.

5.3. The User warrants that they are the lawful owner or authorized user of the registered card.

Article 6 — Payment Authorization

6.1. For certain bookings, VrapOn or the PSP may carry out a preliminary authorization of funds to verify the validity of the card and the availability of funds.

6.2. Authorization does not constitute final settlement.

6.3. Release of the authorized funds depends on the issuing bank and its operating timelines.

Article 7 — Settlement

7.1. After the trip is completed, the Platform will charge the final fare amount, including any additional charges applicable under the Terms and Conditions.

7.2. In case of a difference between the estimated value and the final fare, the actual amount, calculated according to the trip parameters, will be charged.

CHAPTER IV — CHARGES AND BILLING

Article 8 — Charges

The fare for a trip may consist of: base fare; distance-based charge; time-based charge; waiting fee; cancellation fee; "No Show" fee; other charges published on the Platform, which are in accordance with the official rates under applicable transport and taxi legislation set by each city's Municipal Council Decisions.

Article 9 — Price Transparency

9.1. VrapOn seeks to display an estimated fare before the booking is confirmed.

9.2. This estimate is indicative and the final fare may change due to: changes to the route; additional stops; waiting time; deviations requested by the Passenger; other factors related to the trip.

Article 10 — Electronic Invoices

10.1. After the payment is completed, VrapOn may issue an electronic invoice or payment confirmation.

10.2. The electronic document will be available in the application or sent to the registered email address.

CHAPTER V — FAILED PAYMENTS

Article 11 — Payment Failure

If a payment cannot be processed due to: insufficient funds; refusal by the bank; an expired card; security restrictions; technical issues — VrapOn may: request an alternative payment method; temporarily suspend the use of card payments; restrict access to the Platform until the payment is made.

Article 12 — User Obligations

The User is responsible for: keeping card details up to date; ensuring sufficient funds; not using third-party cards without authorization; promptly reporting any unauthorized use of the account.

CHAPTER VI — PAYMENT SECURITY

Article 13 — Security Measures

VrapOn and its payment partners implement technical and organizational measures to protect transactions, including: encryption of communications; user authentication; monitoring of suspicious transactions; fraud prevention mechanisms.

Article 14 — Strong Customer Authentication

Where required by legislation or card network rules, payments may be subject to strong authentication procedures (e.g. 3D Secure or similar mechanisms).

CHAPTER VII — PAYMENT DISPUTES

Article 15 — Complaints

A User claiming a payment error must contact VrapOn through official channels within a reasonable period from the date of the transaction.

Article 16 — Verification

VrapOn may request: invoices; screenshots; transaction data; identification documents; additional information — to verify the claim, while complying with data protection legislation.

Article 17 — Chargebacks

17.1. If a user initiates a chargeback procedure through their bank or card issuer, VrapOn will cooperate with the payment provider to review the case.

17.2. If it is established that the payment was lawfully made and the service was provided, VrapOn reserves the right to dispute the chargeback procedure and submit relevant evidence.

17.3. Abuse of the chargeback procedure may lead to restriction or closure of the user's account, without prejudice to their right to submit legitimate complaints.

CHAPTER VIII — FINAL PROVISIONS

Article 18 — Changes to the Policy

VrapOn reserves the right to update this Policy to reflect: legal changes; technological developments; new payment methods; changes to payment partners. The updated version is published on the official website and takes effect on the date specified.

Article 19 — Related Documents

This Policy must be read together with: the Terms and Conditions of Use; the Privacy Policy; the Cookie Policy; the Refund Policy.

ANNEX 3 — REFUND POLICY

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

1.1. This Refund Policy ("the Policy") sets out the rules and procedures for reviewing requests for refunds of payments made through the VrapOn Taxi Platform.

1.2. The Policy aims to ensure a fair, transparent, and consistent process for handling user requests, respecting Albanian legislation, payment partner rules, and consumer rights.

1.3. This Policy is an integral part of the Terms and Conditions of Use and must be read together with the Payment Policy.

Article 2 — Scope of Application

2.1. This Policy applies to all payments made through the Platform, including: card payments; payments for transport services; cancellation fees; "No Show" fees; other charges published by VrapOn.

2.2. The Policy does not apply to services provided by third parties (such as hotels, restaurants, flights, ferries, car rentals, or other integrated services), for which any refund request must be addressed to the relevant provider.

Article 3 — Definitions

Refund — the full or partial return of an amount paid by the User.
Full Refund — the return of the entire amount paid.
Partial Refund — the return of part of the amount paid.
Chargeback — a procedure initiated by the cardholder through their bank to dispute a transaction.
Technical Error — a technical issue that has affected the calculation or processing of a payment.

CHAPTER II — CASES WHERE A REFUND MAY BE GIVEN

Article 4 — Full Refund

VrapOn may approve a full refund, among other cases, where: a payment has been made twice for the same trip; the trip was not carried out and the payment was charged in error; a technical error on the Platform has been identified; an unauthorized charge has been made and is confirmed after verification; an incorrect fare has been mistakenly applied; there is a final decision by the competent authority ordering the refund.

Article 5 — Partial Refund

A partial refund may be approved in cases such as: the difference between the estimated fare and the final fare results from a system error; an additional fee has been applied in error; part of the service was not provided for reasons attributable to the Platform; VrapOn decides to offer compensation as a commercial gesture ("goodwill"), without accepting legal liability. Granting such a refund does not create a precedent and does not oblige VrapOn to act the same way in other cases.

Article 6 — Refunds as a Commercial Gesture

6.1. In special cases, VrapOn may decide to offer a refund or credit to the user's account as a commercial gesture, even where no legal obligation exists.

6.2. This does not constitute an admission of fault or liability by VrapOn.

CHAPTER III — CASES WHERE NO REFUND IS GIVEN

Article 7 — General Cases

A refund will not be given, among other cases, when: the trip was carried out as booked; the fare was correctly calculated; the change of route was requested by the Passenger; waiting or "No Show" fees were applied in accordance with the Terms and Conditions; the request is based solely on subjective dissatisfaction, without evidence of a service failure.

7.1 The trip was carried out as booked. No refund is given when: the Driver arrived at the pick-up point and carried out the trip as requested by the Passenger; the fare was calculated according to VrapOn's system; no technical or administrative error is found.

7.2 Waiting fee. If the Driver arrives at the pick-up point and waits for the Passenger, the waiting fee is not refundable if: the Passenger did not show up within the waiting time set in the application; the Driver followed the arrival procedure and was available for pick-up. The standard waiting time is: up to 10 minutes free of charge; after this period, the system may apply a waiting fee; after 15 minutes, the Driver may consider the Passenger a "No Show" and leave.

7.3 "No Show" fee. No refund is given when: the Driver arrived at the pick-up location; waited for the minimum set time; attempted to contact the Passenger, where reasonable; the Passenger did not show up. In these cases, the "No Show" fee is considered earned as compensation for the Driver's time and costs.

7.4 Cancellation after the Driver has set off. If the Passenger cancels the trip after the Driver has accepted the request and started moving toward the pick-up point, VrapOn may apply a cancellation fee. The fee is not refunded when the Driver has travelled a distance of 1km toward the pick-up point, or more than 5 minutes have passed since the trip was accepted. In these cases, the cancellation fee is considered justified.

7.5 Cancellation after the Driver's arrival. If the Driver has arrived at the pick-up point and the Passenger cancels the booking after the Driver's arrival, the cancellation fee is not refundable.

7.6 Change of destination. No refund is given when the final fare changes as a result of: a change of destination by the Passenger; added stops; a request by the Passenger to change the route.

7.7 Additional stops. If the Passenger requests additional stops during the trip, the additional charge calculated by the Platform is not refundable.

7.8 Traffic and road conditions. No refund is given solely due to: heavy traffic; roadworks; forced detours; accidents; road closures; weather conditions.

7.9 Route. No refund is given when the Driver uses an alternative route that is: suggested by the navigation system; requested by the Passenger; necessary due to traffic or safety.

7.10 Cash payments. Where payment is made in cash and the Passenger pays the requested amount at the end of the trip, VrapOn is not liable for returning amounts, except where a clear error in the fare calculation or payment processing is proven.

7.11 Unsupported requests. No refund is given when the request: is not supported by sufficient evidence; conflicts with the data recorded on the Platform; is submitted with false or misleading information.

7.12 Abuse of the Refund Policy. VrapOn may refuse a refund request if it establishes, or has reasonable grounds to suspect, that the user: submits repeated unfounded requests; manipulates the payment system; abuses the chargeback procedure; creates multiple accounts to obtain refunds; acts in breach of the Terms and Conditions or the Anti-Fraud Policy.

Article 8 — Factors Outside VrapOn's Control

VrapOn does not issue refunds solely due to: traffic; weather conditions; accidents; road blockages; delays in arriving at an airport, hotel, restaurant, bus or ferry terminal, or other activity; changes to third-party service schedules.

Article 9 — Third-Party Services

VrapOn is not responsible for refunding payments related to: hotel bookings; restaurant bookings; plane tickets; bus tickets; ferry tickets; car rentals; tourist activities; or any other service provided by a third party. Any claim regarding these services must be addressed to the relevant provider.

CHAPTER IV — REFUND REQUEST PROCEDURE

Article 10 — Submitting a Request

10.1. The User may submit a refund request through VrapOn's official support channels.

10.2. The request should include, where possible: the trip number; the date and time of the transaction; the amount charged; a description of the claim; any supporting evidence.

Article 11 — Deadline for Submission

A refund request must be submitted within 30 (thirty) calendar days from the date of the transaction, in accordance with Article 43 of the Terms and Conditions. Requests submitted after this period may not be verifiable and may be refused, unless the law provides otherwise.

Article 12 — Review of the Request

VrapOn will: verify the trip data; analyze technical and payment records; request additional information, if necessary; notify the user of the outcome of the review within a reasonable period. If the request is approved, VrapOn will process and initiate the return of the amount within 3-5 (three to five) business days from the date of approval, in accordance with Article 44.2 of the Terms and Conditions.

ANNEX 4 — TERMS FOR DRIVERS AND TAXI OPERATORS

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

1.1. This document sets out the conditions governing the use of the VrapOn Taxi Platform by Drivers and Taxi Operators.

1.2. This document is an integral part of the contractual relationship between VrapOn and every Driver or Operator who registers on the Platform.

1.3. By creating an account or using the Platform, the Driver or Operator declares that they have read, understood, and accepted these terms.

Article 2 — Definitions

VrapOn — the technology platform that intermediates transport requests.
Taxi Operator — a natural or legal person holding a license to carry out taxi transport activity.
Driver — the natural person who drives the vehicle and provides the transport service.
Vehicle — the vehicle registered on the Platform and approved for use.
Platform — VrapOn's application and technology systems.

CHAPTER II — REGISTRATION CONDITIONS

Article 3 — Eligibility Criteria

To register on the Platform, the Driver or Operator must meet at least the following conditions: be of legal age; have full legal capacity to act; hold the licenses and authorizations required under Albanian legislation; hold valid identification documents; hold a bank account, where required for payments; accept the Platform's Terms and Conditions.

Article 4 — Mandatory Documentation

The Operator or Driver must submit valid documentation, as applicable, such as: an identification document; a driving license; a taxi transport license; a vehicle registration permit; an insurance certificate; a technical inspection certificate; tax documents, where required; other documents specified by VrapOn or applicable legislation. VrapOn reserves the right to request updates to these documents at any time.

Article 5 — Verification

5.1. VrapOn may verify the accuracy of the submitted documentation.

5.2. VrapOn may refuse registration or suspend access to the Platform if the documents prove to be invalid, forged, or incomplete.

CHAPTER III — THE VEHICLE

Article 6 — Vehicle Standards

The vehicle must: be registered in accordance with the law; be in good technical condition; be clean; have functioning air conditioning, where equipped; be safe for transporting passengers; meet the standards set by legislation and VrapOn.

Article 7 — Inspections

VrapOn may request: photographs of the vehicle; verification videos; physical inspection; additional documentation. Failure to comply with these requests may lead to the vehicle being suspended from the Platform.

CHAPTER IV — DRIVER OBLIGATIONS

Article 8 — Service Standards

The Driver is obliged to: be courteous and professional; comply with the law; comply with the Road Traffic Code; not discriminate against passengers; protect their safety; use the most appropriate route, except where the passenger requests otherwise.

Article 9 — Prohibited Conduct

The Driver is not permitted to: consume alcohol or narcotic substances while working; request payments outside the Platform, where the trip has been booked through VrapOn and payment must be made in the app; manipulate GPS or the application; use another person's account; share the account with unauthorized persons; use vehicles not registered on the Platform; contact passengers for purposes unrelated to carrying out the trip.

CHAPTER V — PAYMENTS AND COMMISSIONS

Article 10 — Payments

Payments for services carried out through the Platform are made according to the procedures published by VrapOn.

Article 11 — Commission

11.1. For use of the Platform, VrapOn may apply a commission on every trip carried out.

11.2. The commission percentage and its method of calculation are set out in the commercial agreement with the Operator or in the policies published by VrapOn.

11.3. VrapOn reserves the right to change the commission, giving Operators reasonable prior notice.

CHAPTER VI — RATINGS AND QUALITY

Article 12 — Rating System

Passengers may rate Drivers after every trip. VrapOn may use these ratings for: monitoring quality; identifying violations; improving the service; decision-making on the suspension or deactivation of an account, where justified.

Article 13 — Complaints

The Driver has the right to submit explanations or evidence regarding a complaint filed against them. VrapOn will review the case impartially and may request additional information from the parties.

CHAPTER VII — SUSPENSION AND CLOSURE OF THE ACCOUNT

Article 14 — Suspension

VrapOn may temporarily suspend the Driver's or Operator's account in the event of: expired documentation; serious violations of these terms; reasonable suspicion of fraud; a risk to user safety; a request from the competent authorities.

Article 15 — Closure of the Account

The account may be permanently closed in the event of: forgery of documents; fraud; use of the account by unauthorized persons; repeated violations of these terms; actions that seriously damage the reputation or security of the Platform. Where possible and appropriate, VrapOn will notify the Driver or Operator of the reasons for the decision and, as applicable, give them the opportunity to provide clarifications.

CHAPTER VIII — PAYMENTS, SETTLEMENT AND FINANCIAL OBLIGATIONS

Article 16 — Calculation of Earnings

The Driver's or Operator's earnings are calculated based on trips carried out and recorded on the Platform. VrapOn maintains an electronic record of all trips, fares, commissions, and payments, which forms the basis for calculating amounts owed to the Operator. In the event of a discrepancy, the data recorded in VrapOn's systems is considered primary evidence, without excluding the Operator's right to present contrary evidence.

Article 17 — Settlement of Payments

Payments to Operators are made according to the payment cycles set out in the commercial agreement or in the policies published by VrapOn. VrapOn may temporarily withhold payments in the event of: a fraud investigation; a chargeback; a dispute over a trip; a request from competent authorities; unpaid obligations owed to VrapOn. Any withholding of funds will be proportionate and only for the period necessary to review the case.

Article 18 — Tax Obligations

Every Operator and Driver is responsible for declaring and paying taxes, contributions, and other fiscal obligations arising from their activity. VrapOn does not act as an employer, tax agent, or guarantor for Operators' fiscal obligations, except where the law provides otherwise.

CHAPTER IX — DATA PROTECTION AND CONFIDENTIALITY

Article 19 — Personal Data

Drivers and Operators are required to process Passengers' personal data only to the extent necessary to carry out the trip. Use of personal data for: unauthorized marketing; private contact; the sale or distribution of data; any purpose not directly related to providing the service, is prohibited. Any violation of this Article is considered a serious contractual breach.

Article 20 — Confidentiality

The Driver and Operator are required to maintain the confidentiality of any non-public information they receive during their cooperation with VrapOn. The confidentiality obligation continues even after the end of the contractual relationship.

CHAPTER X — USE OF THE PLATFORM

Article 21 — Permitted Use

Drivers and Operators must use the Platform only for: accepting trips; carrying out transport; necessary communication with Passengers; managing their account.

Article 22 — Prohibited Actions

The following are prohibited: modifying the application; reverse engineering; using bots or automated programs; interfering with VrapOn's IT systems; using applications to manipulate GPS; artificially generating trip requests; colluding to defraud the Platform.

CHAPTER XI — INTELLECTUAL PROPERTY

Article 23 — Ownership Rights

All rights to the Platform, application, trademarks, logos, designs, source code, databases, and other materials belong exclusively to Upfront Albania sh.p.k. or its licensors. Registration on the Platform does not grant the Driver or Operator any ownership right over these elements.

Article 24 — VrapOn Trademark

Drivers and Operators may not use the VrapOn name, logo, or trademark: for personal advertising; on social media in a way that creates the impression of an official statement; for political purposes; for activities that could damage the Platform's reputation. Use of the mark is permitted only in accordance with VrapOn's written guidance or authorization.

CHAPTER XII — AUDIT AND CONTROL

Article 25 — Verifications

VrapOn may carry out verifications regarding: the validity of licenses; documentation; insurance; vehicles; activity on the Platform; compliance with these Terms. Drivers and Operators are required to reasonably cooperate during these verifications.

Article 26 — Updating Documents

Drivers and Operators must promptly update any document that expires or changes. Failure to submit updated documents in time may lead to suspension of access to the Platform.

CHAPTER XIII — LIABILITY

Article 27 — Liability of the Driver and Operator

The Driver and Operator are liable for: compliance with Albanian legislation; vehicle safety; the validity of documents; conduct while providing the service; damages caused by their actions or omissions.

Article 28 — Limitation of VrapOn's Liability

VrapOn is a technology platform that intermediates transport requests and is not a transport operator, vehicle owner, or employer of Drivers. To the extent permitted by law, VrapOn is not liable for: road accidents; vehicle damage; damage to personal belongings; loss of profit; indirect or consequential damages; acts or omissions of Drivers or Passengers beyond its control. This limitation does not apply in cases where liability cannot be excluded under applicable legislation.

CHAPTER XIV — TERMINATION OF THE RELATIONSHIP

Article 29 — Termination by the Driver or Operator

The Driver or Operator may stop using the Platform at any time by closing the account and settling any outstanding financial obligations.

Article 30 — Termination by VrapOn

VrapOn may terminate the contractual relationship in the event of: serious or repeated violations; fraud; forged documents; a risk to user safety; a request from competent authorities; failure to comply with contractual obligations. Where possible and appropriate, VrapOn will notify the Operator or Driver and give them the opportunity to provide clarifications before the decision is made.

CHAPTER XV — FINAL PROVISIONS

Article 31 — Changes

VrapOn reserves the right to change these Terms at any time. Changes will be published on the Platform and, where required, communicated to Drivers and Operators before taking effect.

Article 32 — Applicable Law

These Terms are governed by the legislation of the Republic of Albania.

Article 33 — Dispute Resolution

The parties will first attempt to resolve any dispute through good-faith negotiations. If no resolution is reached, the dispute shall be subject to the jurisdiction of the competent courts of the Republic of Albania, unless the law requires a different forum.

Article 34 — Related Documents

These Terms must be read together with: VrapOn's Terms and Conditions of Use; the Privacy Policy; the Cookie Policy; the Payment Policy; the Refund Policy; the Anti-Fraud Policy; the Code of Conduct.

ANNEX 5 — ANTI-FRAUD POLICY

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

1.1. This Policy sets out the measures VrapOn applies to prevent, detect, investigate, and address fraud, abuse, and unlawful activity on the Platform.

1.2. The Policy aims to protect: users; drivers; taxi operators; payment partners; the reputation and integrity of the Platform.

Article 2 — Scope of Application

This Policy applies to: Passengers; Drivers; Taxi Operators; VrapOn Business users; commercial partners; any person who uses or attempts to use the Platform.

Article 3 — Principles

VrapOn follows the principles of: lawfulness; proportionality; confidentiality; transparency; protection of good-faith users; cooperation with competent authorities.

CHAPTER II — FORMS OF FRAUD

Article 4 — Account Fraud

The following constitute fraud: creating fake accounts; using forged identities; using invalid or forged documents; creating multiple accounts to unfairly benefit from promotions; using other people's accounts without authorization.

Article 5 — Payment Fraud

The following are considered serious violations: using stolen or unauthorized cards; providing false payment information; manipulating the payment process; attempts to bypass payment security mechanisms.

Article 6 — Chargeback Abuse

The following are prohibited: initiating chargeback procedures for valid transactions; submitting false claims to the bank; using chargebacks as a way to avoid paying for services already provided. In such cases, VrapOn may dispute the request with the payment partner and take measures against the user.

Article 7 — GPS Fraud

The following are prohibited: manipulating the device's location; using applications to spoof GPS; simulating trips; artificially altering routes; any act intended to affect the fare or operation of the Platform.

Article 8 — Promotion Fraud

The following constitute abuse: using multiple accounts to obtain promo codes; sharing or selling codes where not permitted; using automated tools to obtain offers; any attempt to manipulate promotional campaigns.

CHAPTER III — PREVENTION MEASURES

Article 9 — Monitoring

VrapOn may monitor activity on the Platform to identify unusual patterns or behavior indicating a possible fraud risk, while complying with personal data protection legislation.

Article 10 — Identity Verification

VrapOn may require verification of users' or drivers' identity at any time, including: an identification document; a selfie or biometric verification, where used and permitted by law; confirmation of the phone number; confirmation of the email address; additional documents in case of reasonable suspicion.

Article 11 — Document Verification

VrapOn reserves the right to: verify the validity of documents; request new documents; refuse documents that are unclear, incomplete, or forged.

CHAPTER IV — INVESTIGATION

Article 12 — Initiating an Investigation

VrapOn may initiate an investigation when it: receives a credible complaint; identifies unusual activity; is notified by payment partners; receives information from competent authorities; finds a discrepancy in the Platform's data.

Article 13 — User Cooperation

During an investigation, the User or Driver must cooperate by: providing accurate information; submitting requested documents; not obstructing the verification process. Failure to cooperate may be taken into account when assessing the case.

CHAPTER V — MEASURES AGAINST VIOLATIONS

Article 14 — Administrative Measures

Depending on the nature and severity of the violation, VrapOn may: send a warning; temporarily restrict certain functionalities; suspend the account; permanently close the account; refuse future registrations. Measures will be applied proportionately and, where possible, the user will be notified of the reasons.

Article 15 — Recovery of Losses

Where permitted by law and supported by evidence, VrapOn may seek to recover financial losses caused by fraud or abuse.

Article 16 — Cooperation with Authorities

Where there is reasonable suspicion of criminal activity, or where required by law, VrapOn may cooperate with competent authorities by providing information in accordance with applicable legislation.

CHAPTER VI — PROTECTION OF USERS

Article 17 — Reporting

Users are encouraged to report: fake profiles; fraud; suspicious payment requests; phishing attempts; suspicious behavior on the Platform.

Article 18 — Education

VrapOn may publish guidance and recommendations on security, aimed at raising user awareness and preventing fraud.

CHAPTER VII — FINAL PROVISIONS

Article 19 — Updating the Policy

VrapOn reserves the right to update this Policy to reflect: changes in legislation; technological developments; new fraud methods; new security practices.

Article 20 — Related Documents

This Policy must be read together with: the Terms and Conditions of Use; the Privacy Policy; the Cookie Policy; the Payment Policy; the Refund Policy; the Terms for Drivers and Operators.

ANNEX 6 — PROMOTIONS AND COMMERCIAL OFFERS POLICY

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

This Policy governs the creation, administration, and use of promotions, promo codes, bonuses, promotional credits, referral programs, and any other commercial offer provided by VrapOn. The purpose of this Policy is to: ensure fair treatment of users; guarantee transparency in the use of promotions; prevent fraud and abuse; protect the legitimate interests of VrapOn and its partners.

Article 2 — Scope of Application

This Policy applies to: Passengers; Drivers; Operators; VrapOn Business clients; commercial partners; any user who benefits or attempts to benefit from a promotion.

Article 3 — Definitions

Promotion — any promotional offer provided by VrapOn.
Promo Code — an electronic code that grants a benefit under the terms of a campaign.
Promotional Credit — a monetary or equivalent value that may only be used according to the specified terms.
Referral Program — a program through which users may earn rewards by inviting new users.

CHAPTER II — GENERAL RULES

Article 4 — Right to Offer Promotions

VrapOn may organize promotions at any time. VrapOn is under no obligation to organize promotions on an ongoing basis. Promotions may be limited by: city; user category; payment method; time period; service type; other criteria set by VrapOn.

Article 5 — Duration

Every promotion has a validity period. Upon expiry: the code is automatically deactivated; unused credits may expire, if provided for in the promotion's terms; no right to compensation arises.

CHAPTER III — PROMO CODES

Article 6 — Use

Promo codes: may only be used in accordance with published terms; may not be sold; may not be transferred, except where expressly permitted by VrapOn; have no monetary value outside the Platform.

Article 7 — Limitations

Unless otherwise specified: a code may be used only once; a code may not be combined with other promotions; the code may not be exchanged for cash; the code does not create any ownership right for the user.

CHAPTER IV — BONUSES AND PROMOTIONAL CREDITS

Article 8 — Credits

VrapOn may grant promotional credits for: marketing campaigns; commercial compensation; loyalty programs; referrals; promotional activities.

Article 9 — Use of Credits

Promotional credits: may only be used on the VrapOn Platform; may not be withdrawn as cash; may not be transferred; do not accrue interest; may not be sold.

CHAPTER V — REFERRAL PROGRAM

Article 10 — Invitations

VrapOn may organize referral programs. A user may invite new users in accordance with published terms.

Article 11 — Conditions

A reward may only be granted if: the new user registers validly; the campaign's conditions are met; no fraud is identified; the new user did not previously hold an active account.

CHAPTER VI — PROMOTION ABUSE

Article 12 — Prohibited Actions

The following are prohibited: creating multiple accounts; using false identities; manipulating the system; using bots; buying or selling codes; colluding to unfairly benefit; any act intended to circumvent the terms of a promotion.

Article 13 — Measures

In case of abuse, VrapOn may: cancel the promotion; remove credits; refuse to pay the bonus; suspend or close the account; seek to recover benefits obtained unfairly, where permitted by law.

CHAPTER VII — CHANGES AND CANCELLATION OF PROMOTIONS

Article 14 — Changes

VrapOn may: change the terms of a promotion; extend or shorten its duration; change the eligibility criteria; update the value of benefits. Changes will not affect rights already earned by users, except where cancellation or modification is necessary due to fraud, technical error, or legal requirements.

Article 15 — Cancellation

VrapOn may cancel a promotion: in case of fraud; due to technical errors; for security reasons; for legal requirements; for significant business reasons.

CHAPTER VIII — LIABILITY

Article 16 — Limitation of Liability

VrapOn is not liable for: the loss of promo codes due to user error; the expiry of codes under their terms; technical issues with the user's device or connection; unauthorized use of the account by third parties, where this is not attributable to a security breach by VrapOn.

Article 17 — Technical Errors

In case of technical errors leading to the accidental granting of promotional benefits, VrapOn may correct the error and recover the benefits granted in error, in accordance with the law and after notifying the user.

CHAPTER IX — LOYALTY PROGRAM

Article 18 — Loyalty Program

VrapOn may create a loyalty program to reward active users of the Platform. The program may be based on: the number of trips carried out; the total amount spent; the length of time using the Platform; rating level; participation in promotional campaigns; other criteria set by VrapOn. Loyalty Program benefits do not constitute an ownership right of the user and may be changed or discontinued under this Policy.

Article 19 — Program Tiers

VrapOn may create different loyalty tiers, such as: Standard; Silver; Gold; Platinum; VIP. The criteria for each tier are published on the Platform and may change at any time.

Article 20 — Benefits

Benefits may include: discounts on trips; priority in driver assignment; promo vouchers; promotional credits; offers from commercial partners; access to special services or functionalities. Benefits are personal and may not be transferred, sold, or exchanged for cash, except where VrapOn provides otherwise.

CHAPTER X — PROMOTIONS FOR BUSINESS CLIENTS

Article 21 — Business Programs

VrapOn may offer special promotional programs for VrapOn Business clients. These may include: preferential rates; subsidized monthly limits; company credits; seasonal discounts; personalized offers.

Article 22 — Conditions

Business promotions: may be subject to a separate contract; are not transferable to individuals; may be limited by number of employees or usage; may be discontinued in case of contract breach or unpaid financial obligations.

CHAPTER XI — VOUCHERS AND PARTNER OFFERS

Article 23 — Commercial Partnerships

VrapOn may cooperate with banks, financial institutions, insurance companies, hotels, restaurants, shopping centers, event organizers, or other partners to provide promotions.

Article 24 — Liability for Partner Offers

Where a promotion is offered by a third-party partner, its terms may be set by the partner. VrapOn does not guarantee the quality, availability, or performance of partner services. Any dispute relating exclusively to the partner's service or product will be handled under the partner's terms, without prejudice to any obligations VrapOn may have under the law.

CHAPTER XII — CONTESTS AND SOCIAL MEDIA CAMPAIGNS

Article 25 — Organization

VrapOn may organize: contests; raffles; promotional games; social media campaigns; marketing activities.

Article 26 — Participation Conditions

Unless otherwise specified, participants must: hold a valid account on the Platform; comply with the campaign rules; not use automated tools; provide accurate information.

Article 27 — Selection of Winners

If winners are selected by draw or according to campaign criteria: the process will follow published rules; VrapOn may require identity verification before delivering the prize; VrapOn may disqualify participants who have violated the rules.

Article 28 — Prizes

Prizes may include: free trips; promotional credits; vouchers; products; services; prizes offered by partners. Prizes may not be exchanged for cash, unless VrapOn expressly provides for this.

CHAPTER XIII — USE OF PROMOTIONAL CONTENT

Article 29 — Promotional Materials

With the user's prior consent, where required by law, VrapOn may use: photographs; videos; comments; ratings; success stories — for promotional purposes.

Article 30 — Consent

The user may withdraw consent to the use of their materials at any time, without affecting the lawfulness of any use made prior to withdrawal.

CHAPTER XIV — AUDIT AND CONTROL OF PROMOTIONS

Article 31 — Verification

VrapOn reserves the right to verify any promotional benefit to confirm that it was earned or used in accordance with this Policy.

Article 32 — Correction of Errors

In case of technical, human, or systemic errors resulting in benefits being granted incorrectly, VrapOn may: correct users' accounts; cancel credits granted in error; recover benefits obtained in breach of the terms, in accordance with the law.

CHAPTER XV — SPECIAL PROVISIONS

Article 33 — No Guarantee

Promotions and offers are voluntary and time-limited. VrapOn does not guarantee that a promotion will be offered again or will have the same terms in the future.

Article 34 — Interpretation

In the event of a discrepancy between this Policy and the terms of a specific promotion, the terms of that promotion will apply to the matters it governs, to the extent they do not conflict with the law or the Terms and Conditions of Use.

CHAPTER XVI — FINAL PROVISIONS

Article 35 — Updating the Policy

VrapOn reserves the right to change this Policy at any time to reflect: legal changes; technological developments; new promotional strategies; new anti-fraud practices. The updated version is published on the official website and takes effect on the date specified.

Article 36 — Related Documents

This Policy must be read together with: the Terms and Conditions of Use; the Privacy Policy; the Cookie Policy; the Payment Policy; the Refund Policy; the Anti-Fraud Policy; the Terms for Drivers and Operators.

ANNEX 7 — CODE OF CONDUCT AND COMMUNITY STANDARDS

CHAPTER I — GENERAL PROVISIONS

Article 1 — Purpose

This Code sets out the standards of conduct that apply to all users of the VrapOn Platform. The purpose of this Code is to: ensure safety; promote mutual respect; protect users' dignity; ensure a trustworthy and professional environment.

Article 2 — Scope of Application

This Code applies to: Passengers; Drivers; Operators; Business users; partners; any person who uses the Platform.

Article 3 — Fundamental Principles

Every user must act in accordance with the principles of: respect; professionalism; honesty; cooperation; safety; non-discrimination; accountability.

CHAPTER II — PASSENGER CONDUCT

Article 4 — Obligations

The Passenger must: behave respectfully toward the Driver; provide accurate location information; not damage the vehicle; not interfere with the driving of the vehicle; wear a seatbelt when required by law; comply with the law and the Driver's reasonable instructions.

Article 5 — Prohibited Conduct

The following are prohibited: insults or threats; verbal or physical harassment; discrimination; the use of violence; damaging the vehicle; consuming prohibited substances; transporting prohibited or dangerous items.

CHAPTER III — DRIVER CONDUCT

Article 6 — Professional Standards

The Driver must: be courteous; respect passengers' privacy; provide reasonable assistance when boarding and alighting; keep the vehicle clean and in good condition; drive carefully and in accordance with the Road Traffic Code.

Article 7 — Prohibited Conduct

The Driver must not: request additional fees beyond those set; discriminate against passengers; use the phone in a way that compromises safety while driving; consume alcohol or narcotic substances while providing the service; contact passengers for personal purposes after the trip has ended.

CHAPTER IV — NON-DISCRIMINATION

Article 8 — Equality

VrapOn does not tolerate discrimination on the basis of: gender; age; disability; race; national or ethnic origin; language; religious belief; or any other criterion protected under applicable legislation.

Article 9 — Equal Service

Drivers and Operators must provide the service equally to all users, except where there is an objective and lawful reason to refuse the trip.

CHAPTER V — SAFETY

Article 10 — Safety During the Trip

Both parties must contribute to a safe trip. The Driver: complies with traffic rules; checks the vehicle's condition; stops only in safe locations, where possible. The Passenger: wears a seatbelt; avoids conduct that may distract the Driver; complies with reasonable safety-related instructions.

Article 11 — Emergency Situations

In the event of an accident, threat, or other emergency: the safety of persons takes priority; the parties must contact the competent emergency services, where necessary; the event must also be reported to VrapOn as soon as possible.

CHAPTER VI — COMMUNICATION

Article 12 — Permitted Communication

Communication between the Driver and Passenger must be limited to matters related to carrying out the trip.

Article 13 — Conduct on the Platform

The following are prohibited: the use of offensive language; sending threatening messages; distributing inappropriate content; publishing false information; violating the privacy of other users.

CHAPTER VII — REPORTING VIOLATIONS

Article 14 — Reporting

Any user may report: inappropriate conduct; discrimination; threats; fraud; violations of this Code; safety incidents. Reports must be made in good faith and, where possible, accompanied by relevant information or evidence.

Article 15 — Review

VrapOn will review every report impartially and may: request additional information; contact the parties involved; analyze the data available on the Platform; take appropriate measures depending on the case.

CHAPTER VIII — MEASURES

Article 16 — Disciplinary Measures

In case of a violation of this Code, VrapOn may: issue a warning; restrict certain account functionalities; temporarily suspend the account; permanently close the account; refuse future registrations, where justified by the nature of the violation. Measures will be proportionate to the severity of the violation and, where possible, the user will be notified of the reasons.

Article 17 — Cooperation with Authorities

Where there is suspicion of a legal violation, or where required by applicable legislation, VrapOn may cooperate with competent authorities by providing information in accordance with legal requirements and personal data protection rules.

CHAPTER IX — FINAL PROVISIONS

Article 18 — Updates

VrapOn may update this Code to reflect: legal changes; new safety practices; technological developments; improvements to community standards. The updated version is published on the official website and takes effect on the date specified.

Article 19 — Related Documents

This Code must be read together with: the Terms and Conditions of Use; the Privacy Policy; the Cookie Policy; the Payment Policy; the Refund Policy; the Anti-Fraud Policy; the Terms for Drivers and Operators; the Promotions Policy.