TERMS AND CONDITIONS OF USE

1. Identity of the provider, scope, and recipients of the Service

The digital platform “21 APP” (the “Platform”) is provided by 21 APP S.r.l., with registered office at Via Lorenzo Perosi, 3 30030 Pianiga (VE), tax code and VAT number 05625570261, registered in the Venice Business Register, REA VE-471117, PEC 21app.art@legalmail.it, email app@21app.art (hereinafter, “21 APP”).

These General Conditions of Use ("GCU") govern access to and use of the Platform and the digital, informational, promotional, organizational, and intermediation services made available by 21 APP, including services reserved for Registered Users, such as cataloging in the Private Ledger, publishing Works, managing purchase requests, operational assistance, and ancillary functions.

The Services are provided exclusively in Italy and are intended solely for residents (natural persons or taxable entities as defined under DPR 633/72) or established in Italy; in the case of taxable entities, they must necessarily have an Italian VAT number. Notwithstanding the previous paragraph and limited to the purchase of the Service by a non-resident natural person, 21 APP may provide the service subjecting the transaction to VAT. In the absence of such conditions, 21 APP reserves the right not to execute the Services.

The limitation referred to in the previous paragraph is established in light of the current operational perimeter of 21 APP and the needs for legal, tax, logistical, AML/KYC compliance, traceability of commercial operators, and verification of the applicable regulations for cultural goods. This limitation does not affect technical access to the Platform by parties not meeting the requirements, provided that such parties may not in any case use such Services or reserved functionalities.

21 APP may condition the registration, activation of features, purchase of subscriptions, publication of Works, submission or acceptance of orders, and execution of individual Services on the verification of territorial requirements and the requested documentation. In the event of a lack, incompleteness, inaccuracy, or subsequent loss of territorial or operational requirements, 21 APP may refuse registration, suspend the Account, limit individual features, not process the order, or cancel the procedure before the conclusion of the contract, notifying the User in the manner provided for in Article 18.

2. Contractual documents and precedence

These GCU constitute an integral part of the contractual documentation governing the relationships between 21 APP and the User.

Depending on the service actually used, the following also apply, if and as relevant: a) the General Terms and Conditions of Sale; b) the General Terms and Conditions of Purchase; c) the conditions of the individual transaction; d) the Work Sheet; e) the Privacy Policy.

In case of conflict, the following shall prevail in order: 1) the mandatory legal provisions; 2) the specific conditions of the individual transaction accepted by the parties; 3) the General Terms and Conditions of Sale and the General Terms and Conditions of Purchase, where applicable; 4) the Subscription Terms; 5) these General Terms of Use.

For Consumers, the mandatory rights provided by Legislative Decree 206/2005 (Consumer Code) remain unchanged; any incompatible clause is deemed to be replaced by the applicable mandatory regulations.

3. Definitions

For the purposes of these T&Cs, it is understood:

• Buyer: the subject, whether a natural or legal person, who, within the limits of the service, purchases or intends to purchase a Work through the Platform, as a Consumer or Professional.

• Account: the personal profile created by the User through the registration procedure on the Platform, associated with the relevant access credentials and containing the data, information, preferences, and permissions related to the User.

• Cultural asset: the asset falling within the scope of application of Legislative Decree 42/2004 (Code of Cultural Heritage and Landscape) according to the applicable regulatory qualification from time to time.

• Consumer Code: Legislative Decree of September 6, 2005, no. 206, and subsequent amendments and additions.

• Contents: texts, images, documents, data, descriptions, videos, certificates, and other materials entered or transmitted by Users;

• Consumatore: persona fisica che agisce per scopi estranei alla propria attività imprenditoriale, commerciale, artigianale o professionale;

• Opera: bene artistico o da collezione oggetto di catalogazione, promozione, valutazione, vendita presente, venduto e consegnato in Italia;

• Platform: individually or jointly, (i) the website and any other domain, subdomain, or web address attributable to it or redirecting to it; (ii) the mobile applications (for iOS, Android, or other operating systems) made available by 21 APP; (iii) the assisted or conversational sales tools, including commercial messaging services, chatbots, and live shopping/live streaming systems, used directly by 21 APP.

• Professional: the operator (natural or legal person) who acts for purposes related to their entrepreneurial, commercial, artisanal, or professional activity.

• PSP: prestatore di servizi di pagamento autorizzato utilizzato nell’ambito della Piattaforma per gestire i flussi finanziari;

• Services: digital, informational, promotional, organizational, and intermediation services made available by 21 APP through the Platform, including the benefits of the Registered User, cataloging in the Private Ledger, publication of Works, management of purchase requests, operational assistance, and ancillary functions.

• Online intermediation services: the services that allow commercial users to offer goods or services for the purpose of initiating direct transactions.

• Work Sheet: page of the Platform related to a specific Work;

• Durable support: any tool that allows the User to store information personally directed to them in an accessible manner for an adequate period and that allows the unchanged reproduction of the stored information;

• General Terms and Conditions of Sale. Indicates the general terms and conditions of sale of the Works and the related mandate contract.

• General Terms and Conditions of Purchase. Indicates the general terms and conditions for the purchase of Works and the related mandate contract.

• Registered User: the status of the User who has completed the registration and Account creation procedure, accessing the benefits and reserved Services of the Platform.

• Utente: chiunque acceda, navighi o si registri alla Piattaforma;

• Seller: the entity, whether a natural or legal person, who, within the limits for the service, sells or intends to sell a Work through the Platform, as a Consumer or Professional.

• Professional Seller: a subject who offers Works for sale in the exercise of their entrepreneurial, commercial, artisanal, or professional activity;

• Non-Professional Seller: a person who offers Works for sale outside of their entrepreneurial, commercial, artisanal, or professional activities;

4. Registration, conclusion of the contract, and obligations of the User

Access to the reserved features of the Platform requires the creation of a personal Account. The User guarantees that the data provided during registration on the Platform is truthful, up-to-date, complete, and refers to the User themselves, and commits to promptly communicate any relevant changes.

The User, a natural person, declares to be of legal age and capable of acting. The User acting on behalf of a legal person, entity, or organization declares to have the necessary powers of representation and to be authorized to bind the represented party.

Access credentials are personal and non-transferable. The User is responsible for their safekeeping and for all activities carried out through their Account. The User agrees to promptly notify 21 APP of any unauthorized access or use of their Account. Multiple, fictitious, or third-party accounts are not permitted.

The use of sales, purchase, or other Services offered subject to legal checks may be contingent upon the completion of identification procedures, document verification, and due diligence required by 21 APP or the appointed PSPs, including AML/KYC checks and tax compliance.

If the information provided is found to be inaccurate, incomplete, outdated, or unverifiable, 21 APP may request the User to remedy this without delay and, in the event of failure to regularize within 2 working days, suspend or refuse the provision of the Service in relation to the offer of goods or services, according to the methods referred to in art. 15.

The User is required to promptly update any relevant information for the execution of the contract, tax obligations, AML/KYC compliance, traceability of commercial operators, and the security of the Platform.

Before sending an order, requesting a Service, or activating a subscription, 21 APP provides information on the technical steps for concluding the contract, on correcting input errors, on the storage and accessibility of the contract, on the available languages, and on means of dispute resolution.

21 APP sends, without unjustified delay, an electronic confirmation of the activation of the Account or the order, containing a summary of the applicable conditions.

5. Benefits of the Registered User and Access Levels

Registration on the Platform grants the User the status of Registered User, ensuring immediate and free access to the Services and functionalities of the 21 APP ecosystem, according to the profiling levels made available on the Platform (for example: Essential, Collector, Dealer, V.I.P.).

The benefits and functionalities included for the Registered User include, depending on the level of profiling and verification of the User:

1. Private Ledger: features for cataloging, archiving, and digital management of one's art collections.

2. Market Transparency: clear display of list prices and estimates of the Works in the catalog.

3. Personal Wishlist: tools for selecting and monitoring Works of interest.

4. Direct Acquisition: enabling secure and confidential purchasing on the Managed Marketplace.

5. Market Placement: enabling the sale of one's Works with a guarantee of anonymity and transactions protected by Escrow mechanisms.

6. Fine Art Services & Club Events: priority access to appraisal, logistics, due diligence services, and accreditation for community events.

The activation of buying and selling features (Direct Acquisition and Market Placement) or access to specific advanced services requires the completion of document checks, AML/KYC, and separate acceptance of the General Terms of Sale and/or Purchase.

21 APP reserves the right to modify, expand, or update the features and benefits included in the Registered User account for organizational, security, or platform evolution needs, providing appropriate communication to Users.

6. Role of 21 APP and transactions

21 APP operates as a provider of the Platform and the related digital services. In its capacity as an online brokerage service provider, 21 APP is not the author of the Content uploaded by Users nor does it assume the role of seller of the Works.

Salvo quanto diversamente indicato nei documenti contrattuali applicabili al singolo Servizio, 21 APP può operare quale mandatario con rappresentanza del Venditore ai sensi dell'art. 1704 c.c., agendo in nome e per conto del medesimo nella conclusione del contratto di compravendita con l'Acquirente, nei limiti del mandato e della procura conferiti.

When 21 APP acts as an agent with the Seller's representation, the sales contract is concluded directly between the Seller and the Buyer;

The Seller remains responsible, within the limits of the law and applicable contractual documents, for the ownership, provenance, authenticity, compliance, legality, description, availability, and delivery of the Work, as well as for any applicable warranty obligations and the right of withdrawal.

The representation of the Buyer does not automatically result from registration, use of the Platform, or submission of the Order, but requires specific, express, and separate consent from the acceptance of these Terms and Conditions, indicating the scope of the powers granted, any fees, operational limits, and measures taken to manage potential conflicts of interest arising from dual representation.

7. Information on Works and Sellers

21 APP makes available on the Platform or through other means of communication, before the conclusion of the order, the pre-contractual information required by applicable law, either directly or by reference to the Product Sheet, the sales conditions, and the Subscription Terms. The clauses and general conditions of the contract are made available to the User in such a way that they can be stored and reproduced.

The information and documents related to the Work are provided by the Seller under their own responsibility, except for services independently provided by 21 APP.

If the Seller is not a Professional, 21 APP informs the Consumer Buyer before the conclusion of the contract, specifying that certain rights provided by the Consumer Code in relationships between professionals and consumers do not apply in the direct relationship between the Buyer and the Non-Professional Seller, without prejudice to the regulation of services directly provided by 21 APP.

The process of submitting the Order is structured to allow the User to identify and correct any input errors before the final submission. 21 APP confirms without unjustified delay, electronically and on a durable medium, the receipt of the order and the summary of the essential conditions of the transaction.

In cases where the submission of the order involves a payment obligation for the Consumer for the purchase of a Work or an on-demand Service, the final button or command through which the User confirms the purchase bears an unequivocal formulation equivalent to "order with payment obligation" or another unambiguous expression.

8. Works of art, provenance, and cultural goods

The Seller declares and guarantees that the Work is in its legitimate availability, that its offering for sale does not violate third-party rights or legal constraints, and that the documentation related to authenticity, attribution, provenance, any cultural constraints, transfer notice, preemption, free circulation, licenses or authorizations is complete, truthful, and up to date as of the date of publication of the Work on the Platform.

21 APP may request certificates, condition reports, declarations, attestations, licenses, information, and additional documentation before or after the publication of the Work.

In case of reasonable doubts regarding the legality of the circulation of the Work, or in the presence of reports, disputes, or orders from the authorities, 21 APP may suspend the operation, remove or make the listing invisible, suspend the execution of logistical or administrative activities, suspend the release of funds, and cooperate with the competent authorities, notifying the interested parties within the limits permitted by law.

The User acknowledges that, for certain categories of Works or specific circumstances, the operation may be subject to further checks regarding resale rights, VAT margin scheme, provenance from third countries, application of cultural heritage regulations, and related tax or documentary obligations. The relevant thresholds and operational conditions must be verified individually for each transaction.

9. AML/KYC, tax, and traceability checks

21 APP, also through third parties appointed or the PSP, may request at any stage of registration on the Platform, use of the Services, or execution of the individual transaction: identity documents, tax code or VAT number, beneficial owner data, bank and payment details, documentation on the source of funds, relevant tax information, and any further documentation necessary for purposes of adequate verification, fraud prevention, anti-money laundering, traceability of commercial operators, tax compliance, and security of the Platform.

The User agrees to cooperate promptly and fully with the requested checks, providing authentic and up-to-date documentation. The failure to submit the requested documentation in a timely, complete, or correct manner constitutes grounds for suspension or limitation of the Account's functionalities, failure to publish the Work, refusal of the order, or closure of the Account, applied in a proportionate manner and in compliance with legal obligations.

The User acknowledges that 21 APP may communicate the collected data to the competent authorities, to PSPs, and to the parties involved in the execution of the Service, within the strictly necessary limits for the fulfillment of legal, tax, AML/KYC, traceability, and security obligations of the Platform, as indicated in the Privacy Policy.

10. Payments and PSP

Payments related to the purchase of Works, brokerage fees, or any on-demand ancillary Services are managed by one or more third-party authorized payment service providers (PSPs) (e.g., Stripe) through direct debit mechanisms, escrow deposits, accounting segregation, or other equivalent technical solutions.

21 APP is not a payment service provider and does not provide banking or financial services, except as strictly required by law.

The indicative timelines for authorization, fund acquisition, release, reversal, or refund are specified in the conditions of the individual operation or Service or in the PSP documentation. 21 APP provides, upon the User's request, a summary of the payment status and any obstacles to the release of the amounts.

21 APP may suspend the execution of a Service, delivery, or payment in the presence of non-confirmation of payment, disputes, document checks, suspicions of fraud, legal obligations, or other circumstances provided for in the general terms and conditions of sale.

11. Ranking, editorial content

The display order of the Works may depend, in particular, on relevance to the search, the completeness and quality of the Work Sheet, the availability of the Work, the category, the documentary status, the reliability of the User, and any editorial selections.

Any sponsored, promotional content or advertisement whose visibility is influenced by an economic consideration or a specific business relationship is clearly and recognizably identified as such for the User, in accordance with applicable regulations.

12. User Content and Intellectual Property

The User guarantees that they have all the rights and permissions necessary to upload, use, and license the Content entered into the Platform (including the data entered in the Private Ledger and in the Work Sheets).

The User retains rights to the Content uploaded to the Platform, but grants 21 APP a non-exclusive, free, revocable license within the limits of legal and contractual obligations, for the duration necessary for the provision of the Services, limited to the following purposes: operational management of the Platform, publication and promotion of the Works, security and technical archiving, execution of the Services, protection of 21 APP's rights, and fulfillment of legal obligations.

The license terminates with the public removal of the Content, subject to the retention of backup copies and documents necessary for 21 APP to fulfill legal obligations, defend rights, or manage disputes.

All intellectual property rights on the Platform, on the software, on the layouts, on the distinctive signs, on the databases, on the editorial content, and on the graphic elements of 21 APP remain the exclusive property of 21 APP or its licensors. No provision of these Terms and Conditions transfers to the User any intellectual property rights on the Platform or its components.

21 APP is not subject to a general obligation to monitor the User's Content nor to a general obligation to actively ascertain facts or circumstances indicating illegal activities. However, 21 APP may carry out voluntary checks, correct manifest errors, and standardize formats, without this implying the assumption of such an obligation.

13. Prohibited Uses

It is prohibited to use the Platform in violation of the law, the rights of third parties, these Terms and Conditions, or the instructions reasonably given by 21 APP for the safety and regular operation of the Service.

In particular, it is prohibited: a) to upload false, illegal, defamatory, misleading content, harmful to third-party rights, or otherwise non-compliant with the law;

b) to publish Works lacking the necessary legal availability or the required documentation;

c) to circumvent technical or procedural security measures of the Platform;

d) to use automated systems – including bots, scrapers, or similar tools – in a way that compromises the regular functioning of the Platform;

e) extract, copy or systematically reuse data or content from the Platform without the written authorization of 21 APP;

f) evade the brokerage fees or the tracking systems provided for the operations;

g) conduct transactions outside the Platform regarding Works for which the sales procedure has been initiated or a confidentiality/exclusivity obligation is in effect.

It is also expressly prohibited to use data, images, texts, metadata, or other content from the Platform – regardless of the format or means of access – for training, development, validation, benchmarking, or optimization of artificial intelligence models or systems, without the prior written consent of 21 APP and any rights holders of the relevant content.

14. Moderation, reports and measures

21 APP provides Users with a dedicated electronic contact point (app@21app.art) for submitting reports related to content, offers, accounts or conduct deemed illegal, inaccurate, harmful to third-party rights or not compliant with these Terms of Service. The report must contain: a) the indication of the contested content or account; b) the reasons for the contestation; c) the contact details of the reporter.

21 APP may adopt, in a proportionate and justified manner, measures for removal, obscuring, visibility limitation, suspension of payments or functionalities, or closure of the Account, in the presence of: a) violations of law or these Terms of Service; b) orders or requests from the competent authority; c) risks to the security of the Platform, fraud or abusive conduct; d) illegal content or harmful to third-party rights; e) failure to provide documentation as required.

When 21 APP adopts a restrictive measure against a User, it communicates to them the essential reasons for the measure and the available remedies, unless such communication is prohibited by law, may compromise investigations or jeopardize the security of the Platform.

15. Sospensione, chiusura dell’account e cessazione

21 APP may suspend or limit access to the Platform or to individual features, or terminate the relationship with the User, in a proportionate and justified manner, in the presence of: a) violation of the Terms of Service or related documents; b) provision of false or unverifiable information; c) failure to cooperate with AML/KYC or tax checks; d) well-founded risk of fraud or money laundering; e) unlawful use of the Account; f) orders from the authority.

In relation to Professional Sellers, 21 APP communicates the reasons for the suspension or termination of Services on a durable medium with reasonable notice, except in cases of urgency, fraud, orders from the authority, or protection of third parties.

The suspension or closure of the Account does not affect the transactions already completed, except in cases of impossibility, illegality, or fraud.

The User may at any time withdraw from this contract and request the closure of their Account by sending a communication to app@21app.art or through the appropriate function available in the reserved area, while remaining bound by the obligations related to transactions already completed, the documents to be retained by law, and tax compliance.

16. Liability

21 APP provides its Services with the professional diligence required by the nature of the activity carried out, within the limits of its role as a provider of the Platform and, where applicable, as a representative agent.

The statements regarding the Work, its ownership, authenticity, provenance, compliance, and the legality of its circulation remain the sole responsibility of the Seller, according to the law and the applicable contractual documents.

21 APP is not responsible for service disruptions attributable to third-party suppliers, PSP, communication networks, force majeure events, authority measures, user conduct, or information provided by sellers.

All mandatory rights provided by law remain firm for consumers. In relations with non-consumer users, except in cases of willful misconduct, gross negligence, and mandatory regulations, 21 APP's overall liability for damages directly resulting from the non-fulfillment of its contractual obligations is limited to the greater of: (i) the amount of the brokerage fee received by 21 APP for the specific transaction to which the damage refers; and (ii) the total sum of 500.00 euros (five hundred/00).

Neither party is responsible for non-fulfillment or delay due to exceptional and unpredictable events beyond their control. The impeded party shall promptly notify the other; if the impediment lasts more than 60 days, either party may withdraw without charges.

17. Privacy and confidentiality

21 APP processes the personal data of users, including buyers and sellers, as the data controller, in compliance with Regulation (EU) 2016/679 (GDPR) and applicable national legislation, as described in the Privacy Policy available on the Platform.

21 APP keeps the identity of buyers and sellers confidential from the public during the provision of services. This confidentiality does not constitute absolute anonymity towards the Platform and does not prevent the necessary processing for the execution of the service or compliance with legal obligations (AML/KYC, tax traceability).

The identity and personal data of the parties may be communicated to PSPs, couriers, authorities, and suppliers involved to the strictly necessary extent for the execution of the operation or to comply with legal obligations, as specified in the Privacy Policy.

18. Communications and complaints

Contractual communications take place via e-mail, certified e-mail, reserved area, in-app notifications, or other suitable tools on durable media.

Promotional communications are sent in compliance with applicable regulations and allow for the withdrawal of consent at any time.

Complaints can be sent to the e-mail address app@21app.art. 21 APP confirms receipt within 3 working days and provides a reasoned response within 7 working days (extendable to 14 for complex cases). For Consumers, all legal remedies remain available.

19. Changes to the Terms and Conditions

21 APP may modify these Terms and Conditions for legal, regulatory, technical, security needs, or to adapt the operational model of the Platform.

Changes are communicated to Users with at least 15 days' notice via in-app notification, e-mail, or publication on the Platform. For commercial users, changes are communicated on durable media.

Changes do not apply retroactively to completed transactions. The User who does not wish to accept the changes may withdraw by requesting the closure of the Account before the effective date of the changes.

20. Applicable law and competent court

These Terms and Conditions and any legal relationship arising from the use of the Platform are governed by Italian law.

For disputes in which a Consumer is a party, the competent judge is the one in the place of residence or domicile of the Consumer, if located in Italy. For disputes with Users who do not qualify as Consumers, the exclusive jurisdiction is the Court of Venice, unless otherwise provided by mandatory law.

21. Artificial intelligence systems and conversational assistant

21.1. Within the Platform and Services, 21 APP may provide registered Users with a conversational assistant based on an artificial intelligence system provided by third parties, intended to provide first-level information and instructions on the use of the Platform and Services (the “Assistant”). The User is informed, in a clear, distinguishable, and accessible manner, no later than at the time of the first interaction, that they are interacting with an artificial intelligence system and not with a physical person. This indication is kept visible and recognizable in the interface of the Assistant. 21 APP may modify, limit, suspend, or deactivate the Assistant, even for technical, security, or regulatory compliance reasons, without this resulting in any rights for the User, while maintaining the availability of human assistance channels. The Assistant is made available without any guarantee of continuity, operating hours, or languages. Changes affecting essential elements of the Services are communicated pursuant to art. 19. The rights recognized to the Consumer and the withdrawal rights provided by the Subscription Terms remain unaffected. 

21.2. The Assistant provides exclusively general information derived from the content of the Platform made available by 21 APP, as well as first-level operational indications on the functionalities of the Platform and the Services. The Assistant does not access the data contained in the Account, the information related to subscriptions, orders, payments, evaluation requests, or other personal information of the User. The Assistant does not modify the Account, does not perform operations, and does not make decisions regarding it. The Assistant does not provide legal, tax, financial, insurance, or investment advice; does not issue appraisals, certificates of authenticity, attribution judgments, estimates, or economic evaluations of the Works; does not replace licensed professionals or experts appointed for evaluation services. The communications generated by the Assistant are merely informative and do not constitute a contractual proposal, acceptance, public offer, commitment, guarantee, waiver, or acknowledgment of rights by 21 APP, nor do they modify, integrate, or derogate from these Terms and Conditions or other applicable contractual documents. No contract, order, mandate, or subscription can be concluded through the Assistant. In case of conflict between the information provided by the Assistant and the contractual documents, the Work Sheet, or the information published on the Platform, the latter shall prevail.

21.3. The Assistant generates responses on a probabilistic basis and may produce inaccurate, incomplete, outdated, or irrelevant information. 21 APP does not guarantee the accuracy, completeness, timeliness, or suitability for a specific purpose of the Assistant's responses. The User is encouraged to verify any relevant information by consulting the official pages of the Platform and the contractual documents or by contacting human assistance before making economic or legal decisions. The User should not rely exclusively on the Assistant's responses. The unwaivable rights recognized to the Consumer remain unaffected.

21.4. The User can request the intervention of a human operator through the Assistant or by using the contact details provided on the Platform. The chat service with an operator is available during the hours communicated on the Platform. Complaints referred to in art. 18 are in any case handled by 21 APP staff.

21.5. Messages entered by the User and the related conversations are processed for the management of the request and any assistance and may be retained for the period necessary to pursue such purposes, as indicated in the Privacy Policy. The User refrains from entering into the Assistant data that is not necessary for the assistance request, personal data related to third parties, special categories of personal data, access credentials, coordinates or data related to payment instruments, as well as confidential information.

21.6. In addition to what is provided by art. 13, it is prohibited: a) to use the Assistant to generate, disseminate or request illegal, misleading, defamatory or harmful content to third parties; b) to attempt to circumvent, alter or evade the instructions, filters and security measures of the Assistant; c) to extract, replicate or systematically reuse the outputs of the Assistant or the data of the Platform to train, develop, validate or optimize models or artificial intelligence systems, in violation of art. 13; d) to use the Assistant for purposes other than those informative and for assistance in using the Platform.

21.7. The User can report malfunctions, inaccurate responses or abnormal behaviors of the Assistant using the contact details indicated in arts. 14 and 18. The User's right to file a complaint with the competent market supervisory authority remains unaffected, as well as, for matters related to the protection of personal data, with the Data Protection Authority.

21.8. Except in cases of willful misconduct and gross negligence and without prejudice to the mandatory rights recognized to Consumers, 21 APP is not liable for damages resulting from decisions made by the User relying solely on the responses of the Assistant, nor for damages resulting from the use of the Assistant in violation of this article. In any case, the limits set forth in art. 16 apply. 

DIGITAL APPROVAL AND ACCEPTANCE (CLICKWRAP)

The acceptance of these General Terms of Use and the related specific approval take place digitally during the registration or first access procedure of the User on the 21 APP Platform, by selecting the appropriate checkboxes and pressing the confirmation button.

[ X ] I fully accept the present General Terms of Use of the 21 APP Platform.

[ X ] Pursuant to and for the purposes of Articles 1341 and 1342 of the Civil Code, I declare that I specifically approve the following clauses:

• Art. 1 and Art. 4: Territorial limitations, access requirements, and the ability to suspend/reject the Account.

• Art. 5: Benefits of the Registered User and the ability to modify functionalities.

• Art. 6: Role of 21 APP as intermediary/mandatary and exclusion of direct liability on transactions.

• Art. 8 and Art. 9: Guarantees on the Works, AML/KYC documentation obligations, and consequences of non-cooperation.

• Art. 10: Management of payments through third-party PSPs and suspension of transactions.

• Art. 12: License on Content uploaded by the User and prohibition of use for AI training.

• Art. 13 and Art. 14: Prohibited uses, moderation tools, and removal/blocking measures.

• Art. 15: Ability to suspend, limit, or close the Account by 21 APP.

• Art. 16: Limitations of liability for 21 APP.

• Art. 19: Ability to unilaterally modify the T&Cs with notice.

• Art. 20: Exclusive jurisdiction of Venice for non-Consumer Users.

• Art. 21: Artificial intelligence systems and conversational assistant.