Fees & Pricing Transparency Policy

Effective Date: 1 July 2026

Last Updated: 1 July 2026

This Fees & Pricing Transparency Policy (the “Policy”) forms part of the contractual framework governing the use of the OXLY platform (the “Platform”) operated by IN SPOT SLU, a company organized under the laws of the Principality of Andorra, with registered office at Carretera d’Engolasters 27A 2-1, Andorra, tax / registration number L-919089-T (“OXLY,” “Company,” “we,” “us,” or “our”).

This Policy applies to pricing, fees, commissions, taxes, disclosures, discounts, estimates, and price-related communications shown on or through the Platform, including in relation to:

• Provider service listings;
• Bookings;
• Subscription plans;
• Promotion Services;
• visibility tools, upgrades, and paid platform features;
• payment-enabled flows, where available.

This Policy supplements the Terms of Platform Use, the Payments & Payout Terms, the Provider Terms, the Booking, Cancellation & Refund Policy, and any service-specific or feature-specific rules shown through the Platform. If there is a conflict between this Policy and a more specific price rule clearly disclosed at checkout or at the time of Booking, the more specific disclosed rule will control for that transaction to the extent permitted by law.

By displaying a price, publishing a listing, offering a service, making a Booking, purchasing a Subscription or Promotion Service, or otherwise using any price-related feature of the Platform, you agree to this Policy.

1. Purpose of This Policy

The purpose of this Policy is to ensure that pricing and fees presented through the Platform are:

• clear;
• accurate in all material respects;
• not misleading;
• not structured to conceal mandatory charges;
• disclosed in a way that supports informed user decisions;
• consistent with applicable law, payment-provider requirements, and Platform rules.

The Platform seeks to promote fair pricing transparency for both Customers and Providers. However, the Company is a technology intermediary and does not assume responsibility for the legality or accuracy of Provider-set prices except to the limited extent expressly stated in Platform rules or mandatory law.

2. Definitions

For the purposes of this Policy:

“Displayed Price” means any price, fee, rate, quote, estimate, or amount shown on the Platform in a listing, checkout flow, booking flow, campaign dashboard, invoice preview, or similar interface.

“Provider Price” means the price set by a Provider for the underlying third-party service offered through the Platform.

“Company Fee” means any fee, commission, service charge, subscription fee, promotional fee, processing-related fee, administrative fee, or similar amount charged by the Company and disclosed through the Platform.

“Mandatory Charge” means any amount that a Customer or Provider must pay as part of the relevant transaction and cannot reasonably avoid if they proceed with the transaction as presented.

“Optional Charge” means an amount that applies only if the User knowingly selects an optional feature, add-on, upsell, or extra service.

“Booking Price” means the total amount payable for a Booking, to the extent payment functionality is enabled.

“Promotion Service” means any paid visibility, advertising, boosting, featuring, or similar digital service sold by the Company.

“Subscription” means any recurring or one-time plan, membership, or paid access product sold by the Company.

3. Core Pricing Transparency Principles

All Users must comply with the following principles:

• prices must be presented honestly and in good faith;
• material pricing information must not be concealed;
• mandatory charges must not be disguised as optional charges;
• the total cost of the transaction should be reasonably understandable before commitment or checkout;
• Users must not use pricing structures, wording, or booking flows to mislead others about the true total amount payable;
• price-related communications on the Platform must be consistent with the actual commercial terms of the service or product being offered.

4. Provider Responsibility for Provider Pricing

Unless the Platform expressly states otherwise, each Provider is solely responsible for:

• setting their own Provider Price;
• ensuring that the price is lawful and accurate;
• ensuring that the price is presented clearly and not misleadingly;
• ensuring that any taxes, levies, or mandatory charges required by law are included or properly disclosed;
• ensuring that any conditions affecting price are stated clearly;
• ensuring that the price corresponds to the actual service offered.

A Provider may not publish a low headline price and then later require the Customer to pay undisclosed mandatory amounts that were not clearly communicated through the Platform before the Booking or order was made.

5. What Must Be Included in a Displayed Price

Where a price is shown for a Provider’s service, Subscription, Promotion Service, or other paid feature, the Displayed Price must accurately reflect the price basis used for that offer.

Where applicable, the Displayed Price or related checkout disclosure must make clear:

• whether the amount is a fixed total price or a starting price;
• whether the amount is hourly, per session, per project, per day, per unit, or based on another pricing structure;
• whether taxes are included or excluded;
• whether any Company Fee applies;
• whether any optional extras may increase the final amount;
• whether the price is subject to booking duration, quantity, travel radius, materials, urgency, or category-specific factors.

If a Provider uses a variable or estimated pricing model, the Provider must clearly indicate that the amount shown is an estimate, starting rate, or rate basis rather than a guaranteed total.

6. Hidden, Misleading, or Unauthorized Charges Are Prohibited

Providers and other Users must not:

• impose hidden fees;
• add undisclosed mandatory charges after a Booking is initiated or confirmed;
• mislabel mandatory charges as optional;
• advertise a price that is not genuinely available under normal booking conditions;
• split one mandatory price into multiple misleading components in order to make the headline amount appear lower;
• conceal taxes, service fees, or mandatory surcharges where law or Platform rules require disclosure;
• use price descriptions that materially misstate what is included.

The Company may investigate and take enforcement action against any listing, price presentation, checkout flow, communication, or conduct that it reasonably believes is misleading, deceptive, unfair, unlawful, or inconsistent with this Policy.

7. Company Fees and Platform Charges

The Company may charge Company Fees in relation to:

• Subscriptions;
• Promotion Services;
• visibility upgrades;
• booking-enabled transactions;
• service-related platform features;
• payment-related operations, where disclosed;
• administrative or recovery charges, where permitted by law and disclosed appropriately.

Where a Company Fee applies, the Company will seek to disclose the nature of that fee through the Platform, checkout, dashboard, pricing page, invoice flow, fee schedule, or other reasonably accessible interface.

The Company may change its fees from time to time in accordance with the applicable Terms and any notice requirements required by law.

8. Provider Fees, Surcharges, and Extras

A Provider may offer or disclose additional charges only if:

• the additional charge is lawful;
• the additional charge is genuine and commercially justified;
• the additional charge is clearly disclosed before the Customer commits to the Booking or order;
• the additional charge is presented in a way that is not misleading.

Examples may include, where lawful and properly disclosed:

• travel surcharge;
• urgent booking fee;
• extra materials fee;
• extended-hours fee;
• additional attendee fee;
• optional premium add-on.

A Provider may not use post-booking private messages, off-platform communications, or last-minute pressure to force a Customer to accept undisclosed mandatory charges.

9. Taxes and Regulatory Charges

Each User remains responsible for their own legal tax obligations unless mandatory law expressly provides otherwise.

Providers are solely responsible for determining whether they must:

• register for tax;
• include tax in the displayed price;
• separately state tax;
• collect and remit tax;
• issue invoices or receipts;
• comply with consumer-pricing disclosure laws.

The Company may, where required by law or operationally appropriate, display tax-inclusive, tax-exclusive, or estimated tax information depending on the jurisdiction, product flow, or service type.

Where taxes are collected, withheld, calculated, or reported by the Company or a Payment Provider, this may be disclosed separately in the relevant flow.

10. Currency and Conversion

Prices may be displayed in euros or in another currency depending on jurisdiction, localization, or product settings.

If the Platform displays a converted or estimated currency amount for convenience, that amount may be approximate only.

The final charged amount may differ due to:

• exchange-rate fluctuations;
• bank or card-provider conversion rates;
• processor charges;
• currency settlement rules.

The Company is not responsible for exchange-rate differences or bank conversion charges imposed by third parties.

11. Booking Prices

If and when Booking Payments are enabled, the Platform may display one or more of the following:

• Provider Price;
• Company Fee;
• tax amount;
• optional extras;
• estimated total;
• final total payable.

Where possible, the Platform will aim to show the Customer the total payable amount before final commitment or checkout.

If the exact total cannot reasonably be determined in advance because the service is variable in scope, hourly, usage-based, distance-based, or dependent on selected extras, the Platform may display:

• a starting price;
• a rate basis;
• a quote;
• an estimate range; or
• another transparent pricing format reasonably suited to the category.

12. Quotes, Estimates, Hourly Rates, and Variable Pricing

A Provider may use quotes, estimates, hourly rates, or variable pricing only if such pricing is presented clearly and not deceptively.

Where variable pricing is used, the Provider must clearly communicate, through the Platform where possible:

• what the quoted amount covers;
• what may cause the price to increase or decrease;
• whether approval is required before exceeding the estimate;
• whether materials, transport, overtime, or extra scope are included or excluded.

A quote or estimate must not be used as a bait price that is materially disconnected from the expected real price under ordinary circumstances.

13. Price Changes Before and After Booking

A Provider may change future prices for future Bookings at any time unless restricted by Platform rules or law.

However, once a Booking is confirmed, the Provider may not unilaterally increase the agreed price for that Booking unless:

• the Platform expressly supports such adjustment;
• the Customer expressly agrees through the Platform or another documented channel accepted by the Company;
• the adjustment is clearly justified by a customer-requested change, scope increase, optional add-on, or another legitimate reason consistent with this Policy.

The Company may disregard or refuse to enforce price changes that are not properly disclosed, agreed, or supported.

14. Price Integrity in Provider Communications

Providers must ensure that any price mentioned in listings, messages, profiles, promotional text, service cards, or other communications remains materially consistent with the actual price they intend to charge.

Providers must not:

• advertise one price publicly and demand another privately without proper basis and prior disclosure;
• pressure Customers to move off-platform to obtain a different mandatory price where Platform rules require in-platform booking or checkout;
• use ambiguous wording to obscure the actual total payable amount;
• manipulate price discussions to avoid Company Fees or Platform controls where such controls apply.

15. Off-Platform Price Evasion and Fee Avoidance

Where the Platform requires certain booking, communication, or payment steps to occur through the Platform, Users must not use pricing or fee discussions to circumvent those requirements.

Without limiting other rules, Users must not:

• encourage off-platform payment solely to avoid Company Fees where the Platform requires in-platform payment;
• reframe the same transaction off-platform after discovery on the Platform in order to avoid mandatory Platform charges;
• use hidden discounts, private invoices, side payments, or disguised charges to defeat Platform-required fee structures.

This clause does not prohibit every off-platform interaction in every circumstance. It prohibits fee evasion, misleading redirection, and circumvention of mandatory Platform pricing or payment controls.

16. Discounts, Promotions, and Coupons

Discounts, promotional prices, coupons, credits, referral benefits, and limited offers must be presented accurately and not misleadingly.

Where a discount is shown, the relevant flow should make clear, where applicable:

• the original reference price;
• the discounted amount or percentage;
• the validity period;
• any conditions of use;
• whether the offer is limited to specific Users, plans, categories, or dates.

Users may not misuse discounts, manipulate promotional mechanics, or combine offers in violation of the applicable promotional terms.

17. Subscriptions and Promotion Services Sold by the Company

For Subscriptions and Promotion Services sold directly by the Company:

• the Company will aim to disclose the applicable price, billing cycle, and included features before purchase;
• recurring billing terms, if any, must be clearly shown before enrollment;
• renewal timing, cancellation rules, and refund treatment are governed by the relevant commercial flow, the Payments & Payout Terms, and applicable law;
• purchase of promotional visibility does not guarantee views, clicks, leads, bookings, or revenue unless expressly stated otherwise.

18. Receipts, Invoices, and Records

Where required by law, by the Platform flow, or by the applicable payment setup:

• the Company or a Payment Provider may issue a receipt or billing confirmation for Company-provided services;
• Providers remain responsible for invoices, receipts, and fiscal documentation relating to their underlying third-party services unless the Platform expressly takes over a specific invoicing function;
• Users are responsible for keeping their own tax and accounting records.

19. Monitoring, Review, and Enforcement

The Company may monitor listings, price displays, checkout flows, price-related messages, discounts, surcharges, and related conduct for compliance with this Policy.

Where the Company reasonably believes that a User has violated this Policy, the Company may:

• request clarification or correction;
• require the User to revise a listing or fee presentation;
• remove or hide pricing information;
• disable a service card or listing;
• cancel or pause a campaign or paid feature;
• restrict booking or payment functionality;
• issue a warning;
• freeze, reserve, offset, or withhold payouts where permitted by law and the applicable payment terms;
• suspend or terminate the relevant Account, role, or feature access.

Where reasonably practicable, the Company will generally seek to issue a warning first. However, the Company may act immediately without prior notice where it reasonably considers immediate action necessary for consumer protection, fraud prevention, regulatory compliance, payment-provider requirements, platform integrity, or urgent operational reasons.

20. Customer Reporting of Pricing Issues

A Customer who believes that a listed or quoted price was misleading, incomplete, or inconsistent with the actual amount demanded may report the issue through the Platform or support channels.

The Company may request evidence including:

• screenshots;
• listing details;
• checkout details;
• messages;
• invoices or receipts;
• proof of payment request;
• any other reasonably relevant materials.

The Company may review the issue for purposes of:

• customer support;
• refund review, where applicable;
• listing moderation;
• trust and safety enforcement;
• payment-risk assessment.

21. No Guarantee by the Company

The Company does not guarantee that every price published by a Provider is lawful, accurate, tax-compliant, or complete.

The Company may take reasonable steps to improve pricing transparency, but:

• the Company does not become the seller of the underlying Provider service solely because a price is displayed on the Platform;
• the Company does not assume responsibility for a Provider’s tax treatment, legal pricing compliance, or commercial practices except to the extent required by law or expressly stated in Platform rules;
• the Company does not guarantee that every estimate or quote will remain unchanged.

22. Disclaimers

To the maximum extent permitted by law, the Company disclaims all warranties, representations, and conditions, whether express, implied, statutory, or otherwise, relating to Provider-set prices, estimates, taxes, surcharge disclosures, or pricing communications.

In particular, the Company does not warrant that:

• every Provider price is lawful in every jurisdiction;
• every Provider has correctly included all taxes;
• every variable estimate will match the final amount;
• every currency conversion display is exact;
• every pricing dispute will result in a refund or enforcement action.

Nothing in this Policy excludes or limits any right that cannot be excluded under mandatory law.

23. Interaction with Refund and Payment Rules

Where payment functionality is enabled, disputes concerning misleading prices, hidden fees, undisclosed mandatory surcharges, or materially inconsistent price presentation may affect:

• refund eligibility;
• partial refund decisions;
• chargeback review;
• payout timing;
• reserve or withholding decisions;
• Provider enforcement outcomes.

All such financial measures remain subject to the Payments & Payout Terms, the Booking, Cancellation & Refund Policy, and applicable law.

24. Changes to This Policy

The Company may update this Policy from time to time.

If material changes are made, the Company may provide notice by posting the updated version on the Platform, updating the Effective Date or Last Updated date, sending an email, publishing an in-app notice, or using another reasonable communication method.

Continued use of the Platform after the effective date of the updated Policy constitutes acceptance of the revised version.

25. Governing Law and Jurisdiction

This Policy is governed by and shall be interpreted in accordance with the laws of the Principality of Andorra, without regard to conflict-of-law principles.

Any dispute arising out of or in connection with this Policy shall be submitted to the competent courts of Andorra, unless mandatory consumer protection law requires otherwise.

26. Contact

IN SPOT SLU

Carretera d’Engolasters 27A 2-1, Andorra

Tax / Registration No.: L-919089-T

Legal contact: a.samoylov@inspot.ad

Support contact: help@oxly.eu