European Union & UK Legal Notices

AQNOVA MARKETPLACE

Global Legal Footer Framework

Comprehensive Compliance & Platform Governance Reference

LEGAL NOTICES & COMPLIANCE DISCLOSURES

Comprehensive Regulatory Compliance Framework for EU & UK Operations

Effective Date: April 7, 2026 | Version 1.0 | Arivon Holding Corporation

This document ("EU & UK Legal Notices") contains all mandatory regulatory disclosures, compliance statements, and legal notices required of AqNova Marketplace, operated by Arivon Holding Corporation ("AqNova"), in connection with its commercial operations targeting users in the European Union, European Economic Area (EEA), and United Kingdom.

This document is divided into two parts: Part A covers European Union legal notices and compliance obligations; Part B covers United Kingdom legal notices and compliance obligations. Where a legal requirement is identical or substantially similar in both jurisdictions, it is addressed in the applicable EU section with UK equivalents noted. Where requirements diverge materially post-Brexit, they are addressed separately.

These notices supplement and are incorporated into the AqNova Platform Terms & Conditions (Section 2) and operate alongside all other Platform Governance Documents. In all matters governed by this document, mandatory EU or UK law prevails over any conflicting Platform terms.

9.2.1 EU Governing Legal Framework — Applicable Regulations & Directives

AqNova's operations in the European Union and the European Economic Area are governed by a comprehensive body of EU law. The following regulations and directives are directly applicable to AqNova's marketplace operations and to the rights of EU users:

9.2.2 EU Online Dispute Resolution (ODR) — Consumer Access & Process

A. What Is the EU ODR Platform?

The EU ODR platform is an interactive website provided by the European Commission that allows consumers and traders to resolve disputes arising from online transactions without going to court. The platform facilitates the connection between consumers and certified Alternative Dispute Resolution (ADR) bodies across EU member states.

The ODR platform is available in all 24 official EU languages and is accessible at https://ec.europa.eu/consumers/odr. It is free to use for consumers and is designed to provide a simple, efficient, and low-cost means of resolving cross-border e-commerce disputes.

B. How to Use the EU ODR Platform

EU consumers who wish to submit a dispute through the ODR platform should follow these steps:

Go to https://ec.europa.eu/consumers/odr and select your language.

Click 'Submit a complaint' and create an account or log in.

Complete the complaint form, providing details of the transaction, the dispute, and the resolution sought. AqNova's ODR contact email is legal@aqnova.co.

The platform will transmit the complaint to AqNova and will propose a certified ADR body where both parties can attempt to resolve the dispute.

Both parties must agree to use the proposed ADR body. If AqNova does not agree, the platform will notify the consumer, who may then pursue other remedies.

The ADR process, if agreed, typically resolves disputes within 90 days.

AqNova's primary internal dispute resolution process (Buyer Protection Program) should be the first point of contact for dispute resolution. EU consumers are encouraged to exhaust the Platform's internal complaint-handling mechanisms before initiating ODR proceedings. Where the internal mechanism fails to resolve the dispute within a reasonable timeframe, EU consumers may proceed directly to the ODR platform.

C. Certified ADR Bodies by EU Member State

AqNova works with certified ADR bodies in key EU member states to facilitate complaint resolution. Where a consumer's national ADR body is not listed, the EU ODR platform will identify the appropriate body. The following are examples of recognized ADR bodies:

9.2.3 Right of Withdrawal — Distance Contracts (EU Consumer Rights Directive)

A. The 14-Day Withdrawal Right — Full Scope

In accordance with Article 9 of Directive 2011/83/EU, EU consumers have the right to withdraw from any distance contract (including all purchases made through the AqNova Platform) within 14 calendar days without giving any reason and without incurring any costs other than those specified below.

The withdrawal period begins on: (a) for goods: the day the consumer (or a third party designated by the consumer, other than the carrier) takes physical possession of the goods; (b) for multiple goods ordered in one order but delivered separately: the day the last item is received; (c) for goods consisting of multiple lots or pieces: the day the last lot or piece is received; (d) for contracts for regular delivery of goods over a defined period: the day the first item is received.

B. How to Exercise the Right of Withdrawal

To exercise the right of withdrawal, EU consumers must inform AqNova (on behalf of the Vendor) of their decision by a clear, unequivocal statement before the expiry of the withdrawal period. This may be done by:

Navigating to 'My Orders' > 'Request Return' in the Platform interface, selecting 'I wish to withdraw from my purchase' as the reason, and submitting the form. This is the preferred and fastest method.

Sending an email to returns@aqnova.co with subject line 'Notice of Withdrawal — Order [Order Number]', clearly stating the items to be returned and the date of the notice.

Using the standard EU Withdrawal Form (available for download in the Platform's Help & Returns section) and submitting it by email to returns@aqnova.co or by postal mail to the registered office address.

Upon receipt of a valid withdrawal notice, AqNova will send an acknowledgment to the consumer's registered email address within 24 hours. The consumer must return the goods to the Vendor (or to an AqNova-designated returns address, where applicable) without undue delay and, in any event, no later than 14 days from the date of notification.

C. Standard EU Withdrawal Form

Pursuant to Annex I(B) of Directive 2011/83/EU, the standard model withdrawal form is reproduced below for consumer convenience. Use of this form is not mandatory — any clear written statement of the intention to withdraw is sufficient.

D. Refund Obligations Upon Withdrawal

Pursuant to Article 13 of Directive 2011/83/EU, upon valid withdrawal AqNova (on behalf of the Vendor) must reimburse all payments received from the consumer, including delivery costs (with the exception of supplementary costs arising from the consumer's choice of a type of delivery other than the least expensive standard delivery offered), without undue delay and in any event no later than 14 days from the day on which the withdrawal notice is received.

AqNova may withhold reimbursement until it has received the returned goods or the consumer has supplied evidence of having returned the goods, whichever is the earlier. Reimbursement will be made using the same means of payment as used for the initial transaction, unless expressly agreed otherwise and provided this does not incur any fees for the consumer.

E. Return Shipping Costs — Rules & Disclosure

The allocation of return shipping costs is as follows:

Standard withdrawal returns: The consumer bears the direct cost of returning goods unless the Vendor has agreed to bear the cost or has failed to inform the consumer that the consumer must bear such costs (in which case the Vendor bears all return costs).

Defective, damaged, or not-as-described goods: The Vendor bears all return costs and must provide a prepaid return label or equivalent.

AqNova's extended 30-day return policy: Where AqNova's 30-day return policy applies (days 15–30), return shipping cost allocation follows the Vendor's stated return shipping policy, subject to Platform minimums disclosed in the Vendor's listing.

F. Exceptions to the Right of Withdrawal

Pursuant to Article 16 of Directive 2011/83/EU, the right of withdrawal does not apply to the following categories of goods (which Vendors must clearly identify in their listings):

Goods made to the consumer's specifications or clearly personalized (custom-made products).

Goods liable to deteriorate or expire rapidly (fresh produce, perishable food items).

Sealed goods that are not suitable for return due to health protection or hygiene reasons and which were unsealed after delivery (including certain personal care, cosmetic, and medical products).

Goods which, after delivery, are by their nature inseparably mixed with other items.

Sealed audio or video recordings or sealed computer software that were unsealed after delivery.

Newspapers, periodicals, or magazines, with the exception of subscription contracts.

Accommodation, transport of goods, car rental, catering, or services related to leisure activities provided on a specific date or period.

Digital content not supplied on a tangible medium, where the consumer expressly consented before delivery began and acknowledged the loss of withdrawal right.

A. Mandatory Pre-Contract Disclosures (CRD Article 6)

Pursuant to Article 6 of the EU Consumer Rights Directive (2011/83/EU), AqNova ensures that the following information is provided to EU consumers in a clear and comprehensible manner before they are bound by a distance contract. This information is provided in the product listing pages, the checkout process, and the Order Confirmation:

B. Contract Confirmation — Article 8(7) CRD

In accordance with Article 8(7) of the Consumer Rights Directive, AqNova provides EU consumers with a confirmation of the concluded contract on a durable medium (email) within a reasonable time after the conclusion of the distance contract, and at the latest at the time of delivery of goods. The Order Confirmation email constitutes this durable medium confirmation and includes all pre-contractual information as set out in Section 9.2.4.A above, or a reference to the document where that information can be accessed.

C. Explicit Payment Obligation — Article 8(2) CRD

Pursuant to Article 8(2) of the Consumer Rights Directive, AqNova's checkout process ensures that the consumer expressly acknowledges the payment obligation before placing the order. The order confirmation button is labeled "Order Now — Pay [Amount]" or equivalent wording that clearly indicates the order entails a payment obligation. Orders confirmed without this acknowledgment are not valid.

9.2.5 EU Digital Services Act (DSA) — Compliance Disclosures

The Digital Services Act (DSA) — Regulation (EU) 2022/2065 — entered into force on November 16, 2022 and has applied in full since February 17, 2024. The DSA establishes a comprehensive regulatory framework for online intermediary services operating in the European Union, with obligations calibrated to the size and type of service provider.

A. Traceability of Traders — Article 30 DSA

Pursuant to Article 30 of the DSA, AqNova requires all traders (Vendors) who offer products or services to EU consumers to provide the following information prior to account activation, and ensures this information is accurate and up to date:

Name, address, telephone number, and email address of the trader.

A copy of the trader's identification document, or equivalent official information for businesses.

The trader's payment account details (where applicable).

The trader's VAT identification number (where applicable).

A self-certification by the trader that they will only offer products and services compliant with applicable EU law.

AqNova makes the following Vendor information available to EU consumers on each product listing page, consistent with Article 30(3) DSA: the trader's name; address; contact details (email and, where applicable, phone); and trader registration numbers where the trader holds such registration. This information is accessible via the 'Seller Information' panel on every listing.

B. Content Moderation & Notice-and-Action

AqNova has implemented a notice-and-action mechanism consistent with Article 16 DSA. Users and third parties may report illegal content or content that violates Platform policies through the following channels:

In-Platform reporting: the 'Report this listing' button, available on every product listing page.

Email reporting: dsa@aqnova.co — for notices submitted pursuant to Article 16 DSA.

For intellectual property infringement notices: dmca@aqnova.co.

AqNova acknowledges valid Article 16 DSA notices without undue delay and takes a decision on the notified content in a timely, non-arbitrary, and objectively justifiable manner. AqNova provides the notifying party with a statement of reasons for any decision taken in response to a DSA notice, consistent with Article 17 DSA.

C. Trusted Flaggers — Article 22 DSA

AqNova cooperates with entities designated as Trusted Flaggers by the Digital Services Coordinator of an EU member state, pursuant to Article 22 DSA. Notices submitted by Trusted Flaggers are processed with priority and with the diligence and promptness required by the DSA. Trusted Flagger status does not exempt notices from individual assessment on their merits.

D. Out-of-Court Dispute Settlement — Article 21 DSA

Pursuant to Article 21 DSA, EU users who disagree with AqNova's decision following an internal complaint may access out-of-court dispute settlement bodies certified by the Digital Services Coordinator of their EU member state. AqNova commits to engage in good faith with proceedings before certified out-of-court dispute settlement bodies and to implement decisions of such bodies that are binding under applicable law.

A list of certified out-of-court dispute settlement bodies is maintained by each EU member state's Digital Services Coordinator and is accessible through the European Commission's DSA transparency database.

E. DSA Internal Complaint-Handling — Article 20 DSA

Pursuant to Article 20 DSA, AqNova maintains an internal complaint-handling system that allows users to lodge complaints about: (a) AqNova's decisions to restrict, remove, or otherwise limit access to content; (b) AqNova's decisions to suspend or terminate accounts; and (c) any other restriction imposed by AqNova in connection with the provision of the service.

Complaints may be submitted to dsa@aqnova.co with subject line 'DSA Complaint — [Nature of Complaint]'. AqNova will handle complaints in a timely, non-discriminatory, non-arbitrary, and diligent manner and will inform the complainant of the outcome and the reasons for AqNova's decision without undue delay.

F. DSA Transparency Reporting

Pursuant to Articles 15 and 24 DSA, AqNova publishes an annual Transparency Report covering: the number and categories of notices received; the number of content moderation actions taken; the number of account suspensions and terminations; the number of complaints received through the internal complaint-handling mechanism; and the outcome of those complaints. The current Transparency Report is accessible at [aqnova.co/dsa-transparency].

G. DSA Single Point of Contact

AqNova's designated DSA point of contact for communication with EU member state authorities and users is:

9.2.6 EU Platform-to-Business (P2B) Regulation — Vendor Disclosures

Regulation (EU) 2019/1150 on promoting fairness and transparency for business users of online intermediation services ("P2B Regulation") applies to AqNova's provision of online intermediation services to business users (Vendors) who have their place of establishment in the EU and who use the Platform to offer goods to consumers located in the EU.

A. Terms & Conditions — Plain Language & Accessibility

Pursuant to Article 3 P2B Regulation, AqNova's terms and conditions for business Vendors are: drafted in plain and intelligible language; easily accessible to Vendors at all stages of the commercial relationship, including before the terms are agreed; and set out grounds for restriction, suspension, or termination in a clear and specific manner.

The full Vendor Terms are accessible at all times at [aqnova.co/vendor-terms]. AqNova provides Vendors with at least 30 days' advance notice (on a durable medium) of any proposed changes to the terms and conditions, except where AqNova is required by law or regulatory order to make immediate changes, in which case Vendors are notified without delay.

B. Ranking Parameters Disclosure — Article 5 P2B

Pursuant to Article 5 P2B Regulation, AqNova discloses the main parameters determining the ranking of product listings in search results and on category pages, as well as the relative importance of those parameters:

AqNova does not accept remuneration from Vendors for improving their ranking in organic search results, except through the disclosed paid promotion features described above. Promoted listings are always clearly labeled and never mixed with organic search results without disclosure.

C. Differentiated Treatment Disclosure — Article 7 P2B

Pursuant to Article 7 P2B Regulation, AqNova discloses the following instances where AqNova or affiliated vendors are given differentiated treatment compared to business users of the Platform:

AqNova does not operate as a direct seller on the Platform. Arivon Holding Corporation does not maintain any Vendor seller account competing with third-party Vendors.

AqNova may feature products from affiliated or partner brands in editorial content, curated collections, and homepage features. Such placements are disclosed as editorial selections and are governed by AqNova's editorial standards, not paid for by the featured Vendors.

AqNova's Founding Vendor Program and seller subscription tiers offer differentiated features and visibility to Vendors based on their plan tier and FVP participation. The criteria for each tier are openly published in the Vendor Agreement (Section 2.2) and on the Platform.

D. Access to Data — Article 9 P2B

Pursuant to Article 9 P2B Regulation, AqNova provides Vendors with access to the following categories of data generated through their Platform activities via the Vendor dashboard:

Transaction data: order volume, GMV, average order value, and conversion rates for the Vendor's listings.

Performance metrics: ODR, dispatch rate, return rate, and Buyer satisfaction scores.

Listing analytics: impressions, click-through rate, and search appearance data for each active listing.

Payout history: full itemized payout records including commission deductions, fees, and net settlements.

AqNova does not share Vendor-generated personal data of Buyers (e.g., buyer contact details, payment information) with Vendors except to the extent necessary for order fulfillment and as required by applicable law. Vendors may not use Buyer personal data obtained through the Platform for any purpose other than order fulfillment and post-sale service related to that order.

E. Internal Complaint Handling — Article 11 P2B

Pursuant to Article 11 P2B Regulation, AqNova maintains a free-of-charge internal complaint-handling system for Vendors. Vendors may submit P2B complaints regarding:

AqNova's alleged non-compliance with obligations under the P2B Regulation that directly affect the Vendor.

Technological changes that materially affect the Vendor's business on the Platform.

AqNova's measures or conduct that materially affect the Vendor's ability to use the Platform.

P2B complaints must be submitted to vendors@aqnova.co with subject line 'P2B Complaint — [Nature of Complaint]'. AqNova will handle P2B complaints transparently, provide reasons for any decision taken in response, and aim to resolve complaints within 20 Business Days of receipt. Complex complaints may take longer, in which case the Vendor will be informed of the expected timeline.

F. External Mediation — Article 12 P2B

Pursuant to Article 12 P2B Regulation, AqNova has identified the following two mediators for the purpose of out-of-court dispute resolution with Vendors:

A. Data Controller Identity

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the data controller responsible for the personal data of EU data subjects collected through the AqNova Platform is:

B. EU Data Subject Rights

Pursuant to Chapter III GDPR, EU data subjects have the following rights in relation to their personal data processed by AqNova:

AqNova's comprehensive data protection practices, including lawful bases for processing, retention periods, international transfer safeguards, and third-party data processors, are set out in the AqNova Privacy Policy (Section 3 of the Platform Governance Documents).

C. EU Supervisory Authorities

EU data subjects may lodge GDPR complaints with the supervisory authority in their member state. The following list includes key supervisory authorities in major EU markets:

A. AqNova's Role as Deemed Supplier

Pursuant to Article 14a of the EU VAT Directive (2006/112/EC, as amended by Council Directive 2017/2455/EU), AqNova is deemed to have received and supplied goods itself where it facilitates, through use of an electronic interface, the following transactions:

B2C distance sales of goods within the EU where the goods are dispatched from outside the EU (import transactions) and the intrinsic value does not exceed EUR 150.

B2C sales of goods within the EU where the Vendor is not established in the EU, regardless of the value of the goods.

In these deemed supplier scenarios, AqNova is responsible for collecting and remitting VAT on the relevant transactions through the Import One Stop Shop (IOSS) scheme or the standard VAT registration regime in applicable EU member states. Vendors involved in deemed supplier transactions are treated as having made a zero-rated B2B sale to AqNova for VAT purposes.

B. One Stop Shop (OSS) Registration

AqNova is registered for the EU One Stop Shop (OSS) VAT scheme to facilitate VAT collection and remittance for qualifying B2C cross-border sales within the EU. AqNova's OSS registration details are available to EU tax authorities upon request. For Vendors who are not deemed suppliers, VAT obligations remain with the Vendor as described in Section 2.2.4 of the Vendor Agreement.

A. EU Omnibus Directive — Price Transparency

Pursuant to Directive 2019/2161/EU (Omnibus Directive), as implemented in national law across EU member states, AqNova requires all Vendors to comply with the following price transparency obligations for promotional pricing:

Any announcement of a price reduction must display the prior price, defined as the lowest price applied by the Vendor in the 30 days preceding the price reduction. References to inflated "original" prices without substantiation are prohibited.

Where a price is personalized on the basis of automated decision-making, the consumer must be clearly informed that the price has been personalized for them.

Consumer reviews published on the Platform are subject to the Omnibus Directive's review authenticity requirements. AqNova verifies that reviews are submitted by users who have actually purchased the reviewed product. AqNova does not publish unverified reviews or allow review manipulation.

B. EU Directive on Empowering Consumers (2024/825/EU)

Pursuant to Directive 2024/825/EU, AqNova and all Vendors operating on the Platform are required to: (a) refrain from displaying sustainability labels that are not based on approved certification schemes or established by public authorities; (b) provide durability information, including a durability score or label where applicable and available; and (c) prohibit advertising goods as available for repair when they are not.

C. EU Product Safety Regulation (EU) 2023/988

Pursuant to the General Product Safety Regulation (GPSR — Regulation (EU) 2023/988), which applies from December 13, 2024, AqNova has implemented the following Platform obligations for products sold to EU consumers:

AqNova maintains an internal product safety contact point accessible to EU market surveillance authorities at: safety@aqnova.co.

AqNova cooperates with the EU Safety Gate (RAPEX) product recall and safety alert system and removes notified unsafe products from the Platform promptly upon receipt of a valid Safety Gate notification.

AqNova requires all Vendors to designate a Responsible Person (Verantwortliche Person) established in the EU for all products sold to EU consumers where EU product safety law requires such designation.

AqNova maintains a dedicated product safety recall section at [aqnova.co/eu-product-safety] listing all active product safety notifications affecting EU Platform consumers.

9.2.10 UK Governing Legal Framework

Following the United Kingdom's withdrawal from the European Union, EU law no longer applies directly in the UK. The UK has retained, assimilated, or replaced most EU-derived consumer and digital legislation with domestic equivalents. The following is the governing UK legal framework applicable to AqNova's UK operations:

9.2.11 UK Online Dispute Resolution & Alternative Dispute Resolution

AqNova is committed to participation in ADR procedures with UK consumers as a means of resolving disputes without recourse to litigation. AqNova will engage with ADR providers certified by the Chartered Trading Standards Institute (CTSI) upon consumer request where the internal complaint-handling process has not resolved the dispute within a reasonable timeframe.

9.2.12 UK Consumer Rights Act 2015 — Statutory Rights

A. Satisfactory Quality (CRA s.9)

Goods must meet the standard that a reasonable person would consider satisfactory, taking account of any description, price, and all other relevant circumstances. Satisfactory quality includes: (a) fitness for all purposes for which goods of that kind are commonly supplied; (b) appearance and finish; (c) freedom from minor defects; (d) safety; and (e) durability. Where goods are sold with knowledge of a specific defect or are sold expressly as "seconds" or "used," the satisfactory quality assessment takes that context into account.

B. Fitness for a Particular Purpose (CRA s.10)

Where a UK consumer expressly or impliedly communicates a specific purpose to the Vendor (or to AqNova) before purchase, and relies on the Vendor's (or AqNova's) skill or judgment in providing goods fit for that purpose, the goods must be fit for that purpose. This right applies even where the particular purpose is not a purpose for which goods of that kind are commonly supplied.

C. Goods Must Match Description (CRA s.11)

Goods supplied must match any description applied to them, including descriptions in the listing, in the advertising, or given by the Vendor in pre-contract communications. Where goods are sold by sample, the bulk must match the sample in quality. A minor discrepancy in color or shade that does not affect the character of the goods may not constitute a breach of the description requirement, but material discrepancies (e.g., different model, specification, or functionality) always constitute a breach.

D. Digital Content — CRA Part 1, Chapter 3

Digital content sold through the Platform (including software, apps, games, films, books, and music supplied in digital form) is subject to the following statutory rights under Chapter 3 of the Consumer Rights Act 2015: the digital content must be of satisfactory quality, fit for a particular purpose, and as described. Where digital content is faulty, the consumer is entitled to a repair or replacement; if these are impossible or inadequate, a price reduction.

E. Services — CRA Part 1, Chapter 4

Services supplied through or in connection with the Platform (including fulfilment services and installation, where offered) must be performed with reasonable care and skill; within a reasonable time; and, where a price is not agreed before the contract is made, for a reasonable price. Where a service does not meet these requirements, the consumer is entitled to have the service performed again or to a price reduction.

A. 14-Day Cancellation Right

Pursuant to Regulation 29 of the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (SI 2013/3134), UK consumers have the right to cancel a distance contract within 14 calendar days from the day after they receive the goods (or the last goods in a multiple-item order), without giving any reason.

To cancel, UK consumers must notify the Vendor (with a copy to AqNova at returns@aqnova.co) before the expiry of the 14-day cancellation period by any clear statement of their decision to cancel. Consumers may use AqNova's online return portal ('My Orders' > 'Request Return') or contact returns@aqnova.co directly. The Cancellation Form reproduced below may be used but is not mandatory.

B. AqNova's Extended 30-Day Return Window

AqNova's Platform return policy offers UK consumers a 30-day return window, which exceeds the 14-day statutory minimum. The additional 16-day window (days 15–30) is provided as a Platform benefit and is not a statutory right; the conditions for the extended window are governed by the Buyer Terms & Protection Policy (Section 2.1).

The statutory 14-day cancellation right and the 30-day return window operate independently. During the statutory 14-day period, the consumer's right to cancel is unconditional (subject to the exceptions set out in Regulation 28 SI 2013/3134). During the extended window (days 15–30), AqNova's Platform return policy applies.

9.2.14 UK GDPR & Data Protection Act 2018

A. UK Data Subject Rights

Pursuant to the UK GDPR and Data Protection Act 2018, UK data subjects have the following rights in relation to their personal data processed by AqNova. These rights are substantively equivalent to EU GDPR rights, with UK-specific procedural elements:

Right of access (UK GDPR Art. 15): Submit SAR to privacy@aqnova.co. AqNova responds within 30 days (extendable to 90 days for complex requests).

Right to rectification (UK GDPR Art. 16): Correct inaccurate data in account settings or by contacting privacy@aqnova.co.

Right to erasure (UK GDPR Art. 17): Request deletion at privacy@aqnova.co. Statutory retention obligations may limit full erasure.

Right to restriction of processing (UK GDPR Art. 18): Request at privacy@aqnova.co.

Right to data portability (UK GDPR Art. 20): Request machine-readable export at privacy@aqnova.co or via 'Download My Data' in account settings.

Right to object (UK GDPR Art. 21): Object to processing based on legitimate interests at privacy@aqnova.co.

Rights related to automated decision-making (UK GDPR Art. 22): Request human review of automated decisions at privacy@aqnova.co.

Right to lodge a complaint: UK data subjects may lodge complaints with the Information Commissioner's Office (ICO) at ico.org.uk or by telephone at 0303 123 1113.

Full details of AqNova's UK data processing activities, international transfer safeguards (including UK International Data Transfer Agreements (IDTAs) and UK Addendum to EU Standard Contractual Clauses), retention periods, and third-party processors are set out in the AqNova Privacy Policy (Section 3).

A. Consumer Rights Enforcement Reform

The Digital Markets, Competition and Consumers Act 2024 (DMCC Act), which received Royal Assent on May 24, 2024, introduces significant reforms to UK consumer law enforcement and consumer rights. AqNova's compliance obligations under the DMCC Act include:

Enhanced consumer rights enforcement: The Competition and Markets Authority (CMA) now has direct enforcement powers against consumer law violations without needing to go to court. AqNova cooperates fully with CMA investigations and information requests.

Fake reviews prohibition: The DMCC Act introduces specific prohibitions on commissioning, hosting, or publishing fake reviews. AqNova's review verification system ensures all published reviews are from verified purchasers. AqNova does not purchase, commission, or manipulate consumer reviews.

Subscription contracts: AqNova's subscription-based seller plans comply with DMCC Act requirements for subscription contracts, including clear disclosure of renewal terms, reminder notices before renewal, and accessible cancellation mechanisms.

B. Digital Markets Regime

The DMCC Act establishes a new digital markets competition regime administered by the CMA, which may designate certain digital platforms as having "Strategic Market Status" (SMS) and impose tailored conduct requirements. AqNova monitors its UK market position and will comply fully with any SMS designation or conduct requirements if applicable.

9.2.16 UK Online Safety Act 2023

The Online Safety Act 2023 (OSA) imposes duties of care on online platforms to protect users from illegal content and, for platforms accessible to children, harmful content. AqNova's compliance obligations under the OSA include:

Illegal content duty: AqNova takes proactive steps to identify, minimize, and remove illegal content on the Platform, including fraudulent listings, counterfeit goods, and content promoting illegal activity.

Safety duties relating to users: AqNova provides clear reporting mechanisms for users to flag harmful or illegal content, and responds to such reports promptly.

Terms of service: AqNova's Platform Terms & Conditions and acceptable use policies accurately reflect AqNova's approach to illegal content and harmful activity.

Transparency reporting: AqNova publishes transparency information about its content moderation practices, accessible at [aqnova.co/uk-safety-transparency].

Ofcom regulation: AqNova cooperates with Ofcom as the UK's online safety regulator and will comply with any Ofcom codes of practice relevant to AqNova's platform classification.

A. Modern Slavery Act 2015 — Transparency Statement

Arivon Holding Corporation is committed to transparency in its supply chains and business operations. In accordance with the Modern Slavery Act 2015 (where applicable based on annual turnover thresholds), AqNova publishes an annual Modern Slavery and Human Trafficking Transparency Statement available at [aqnova.co/modern-slavery-statement]. The statement sets out the steps taken by Arivon Holding Corporation to identify and address the risk of modern slavery and human trafficking in its supply chains and business operations.

AqNova requires all Vendors to represent and warrant that their supply chains are free from forced labor, child labor, and human trafficking in compliance with applicable law. Vendors in high-risk categories or geographies are subject to enhanced supply chain due diligence requirements.

B. UK VAT — Deemed Supplier Rules

Pursuant to Section 47A of the VAT Act 1994, AqNova is treated as the deemed supplier for VAT purposes in connection with certain online marketplace transactions involving non-UK vendors supplying goods to UK consumers. In such cases, AqNova is responsible for accounting for UK VAT on the relevant supply. AqNova's UK VAT registration number is available upon request from tax@aqnova.co.

C. Companies Act 2006 — Platform Operator Disclosure

AqNova's Platform is operated by Arivon Holding Corporation. AqNova does not maintain a separately incorporated UK entity at this time. UK users contract directly with Arivon Holding Corporation. AqNova's registered office and contact information is set out in the contacts section of this document (Section 9.2.20). AqNova will update this disclosure upon any UK incorporation.

D. UK Consumer Credit — Disclosure

Where AqNova or its payment partners offer buy-now-pay-later (BNPL) or other credit facilities to UK consumers in connection with Platform purchases, such facilities are provided by FCA-authorized lenders. AqNova does not itself hold an FCA authorization for the provision of consumer credit. UK consumers are advised to review the terms and conditions of any BNPL or credit facility before proceeding and to ensure the facility is provided by an FCA-authorized firm (registered at register.fca.org.uk).

9.2.18 Accessibility Statement — EU & UK

AqNova is committed to ensuring the Platform is accessible to all users, including persons with disabilities. AqNova's accessibility framework is designed to meet the requirements of the EU Web Accessibility Directive (Directive 2016/2102), the EU Accessibility Act (Directive 2019/882, applicable to digital products and services from June 28, 2025), the UK Equality Act 2010, and applicable public sector accessibility requirements.

AqNova targets compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA across the Platform, including the website, mobile application, and checkout process. AqNova's current accessibility conformance status and known limitations are documented in the AqNova Accessibility Statement, accessible at [aqnova.co/accessibility].

Users who experience accessibility barriers or who require accommodations are invited to contact accessibility@aqnova.co. AqNova will acknowledge accessibility requests within 5 Business Days and will endeavor to resolve substantive barriers within 30 Business Days.

A. EU Green Claims Framework

AqNova's green claims compliance framework for EU operations is governed by: the EU Unfair Commercial Practices Directive 2005/29/EC (as amended by the Omnibus Directive); the EU Green Claims Directive (proposed, COM/2023/166, expected adoption 2025–2026); the EU Empowering Consumers Directive 2024/825/EU; and applicable national implementing legislation. Full details are set out in Section 2.2.2.C of the Vendor Agreement.

AqNova prohibits the following on the Platform for EU-targeted listings: generic unsubstantiated environmental claims ("eco-friendly," "green," "sustainable" without substantiation); claims based solely on carbon offsetting without disclosure of the underlying methodology; and sustainability labels not based on approved certification schemes. Violations are addressed through AqNova's listing compliance review process with referral to applicable national advertising standards authorities where warranted.

B. UK Green Claims Compliance

AqNova's green claims compliance framework for UK operations is governed by: the UK Consumer Protection from Unfair Trading Regulations 2008; the CMA Green Claims Code (published September 2021); the Advertising Standards Authority (ASA) UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code); and the Broadcast Committee of Advertising Practice (BCAP) Code. AqNova cooperates with the CMA and ASA in relation to any green claims investigations involving Platform Vendors.

9.2.20 EU & UK Contact Directory

AqNova Marketplace | Global Legal Footer Framework | Section 9.2: EU & UK Legal Notices

© 2026 Arivon Holding Corporation. All rights reserved. Effective April 7, 2026. Version 1.0.

THIS DOCUMENT IS FOR PLATFORM GOVERNANCE PURPOSES. IT DOES NOT CONSTITUTE LEGAL ADVICE. THE LAWS REFERENCED HEREIN ARE SUBJECT TO AMENDMENT. CONSULT QUALIFIED EU AND UK LEGAL COUNSEL FOR CURRENT JURISDICTION-SPECIFIC GUIDANCE.