Acceptable Use Policy (AUP).

1. Scope

This AUP applies to all businesses, organizations, employees, contractors, developers, and other authorized users using Abelo ("Customers").

For purposes of this AUP, "Customer" means any business or organization that uses Abelo.

"Recipient" means any person or entity to whom a Customer sends, or attempts to send, a communication through Abelo.

This AUP applies to all uses of the Abelo Services, including:

• Viber Business Messages;

• SMS;

• WhatsApp and other channels when made available;

• authentication and OTP messaging;

• transactional and service messaging;

• promotional and marketing messaging;

• APIs and webhooks;

• audience management;

• automated campaigns;

• integrations;

• file uploads; and

• other communication functionality provided by Abelo.

2. General Compliance Obligations

Customers must use Abelo in compliance with:

• applicable laws and regulations;

• data protection and privacy requirements;

• electronic communications and marketing laws;

• telecommunications requirements;

• consumer protection laws;

• applicable sanctions and trade restrictions;

• this AUP;

• the Abelo Terms of Use;

• the Abelo Privacy Policy; and

• the policies, requirements and technical standards of the applicable messaging providers and networks.

Customers are responsible for understanding and complying with the legal requirements applicable to their industry, jurisdiction, communications, and recipients.

3. Customer Responsibility for Recipients and Data

Customers are responsible for ensuring that they have the legal right and appropriate authorization to:

• collect recipient data;

• upload or synchronize recipient data with Abelo;

• send communications to recipients;

• use recipient data for the intended communication purpose;

• use third-party integrations;

• use contact lists;

• use telephone numbers, email addresses, identifiers, or other personal data; and

• retain and process communication records.

Customers must not upload, import, synchronize, or use personal data obtained through unlawful, deceptive, unauthorized, scraped, or otherwise prohibited means.

Customers must maintain appropriate records demonstrating their legal basis, authorization, consent, or other permission where required.

Abelo may request reasonable evidence of compliance where necessary to investigate complaints, regulatory issues, abuse, or violations of this AUP.

4. Consent and Messaging Permissions

4.1 Promotional and Marketing Communications

Customers must obtain and maintain all consent, authorization, or other legal basis required under applicable law before sending promotional or marketing communications.

Customers must honor applicable:

• opt-in requirements;

• unsubscribe requests;

• opt-out requests;

• suppression lists;

• channel preferences;

• do-not-contact requests; and

• other recipient rights.

Every promotional message dispatched via Abelo must include a clear, accessible, and functioning opt-out mechanism (such as the Platform's {{unsubscribe_url}} link, or valid channel-specific opt-out instructions). Customers must never remove, obscure, or tamper with unsubscribe links or instructions.

Customers must not send promotional communications to recipients who have validly withdrawn the relevant permission.

4.2 Transactional and Service Communications

Transactional and service communications may be subject to different legal requirements from promotional communications.

Examples may include:

• order confirmations;

• appointment reminders;

• delivery notifications;

• account notifications;

• service updates;

• payment notifications;

• booking information; and

• other communications directly related to a transaction or service.

Customers are responsible for ensuring that the content and purpose of each communication meet the applicable legal and channel requirements.

4.3 Authentication and OTP Communications

Authentication and one-time-password messages may be used for legitimate authentication, verification, account-security, and access-control purposes.

Customers must not use authentication or OTP functionality to send unsolicited marketing content or unrelated promotional material. Customers must not include promotional text, marketing links, commercial offers, or advertising banners in authentication or OTP messages.

4.4 Accurate Message Classification

Customers must accurately classify communications according to their actual purpose and content.

Customers must not misclassify promotional content as transactional, service, authentication, or other non-promotional communication in order to bypass applicable legal, technical, channel, or commercial requirements. Misclassifying marketing communications as transactional or OTP constitutes a material violation of this AUP and may result in immediate message rejection or suspension by Abelo or messaging networks.

5. Viber Business Messages

Abelo is an official Rakuten Viber Messaging Partner.

Customers using Viber Business Messages through Abelo must comply with:

• applicable Viber Business Messages requirements;

• Viber's applicable commercial and technical policies;

• Viber sender and account requirements;

• Viber content and messaging requirements;

• applicable template requirements;

• recipient consent and communication requirements; and

• any other requirements communicated by Abelo or Rakuten Viber.

Viber requirements may change from time to time. Customers are responsible for complying with the requirements applicable at the time their messages are sent.

Abelo may reject, modify, delay, restrict, or prevent the sending of messages where reasonably necessary to comply with Viber requirements or to protect the integrity and reputation of the messaging service.

6. SMS and Other Messaging Channels

Customers using SMS, WhatsApp, or other supported channels must comply with the applicable requirements of the relevant channel, telecommunications operators, and service providers.

Message delivery may depend on third-party infrastructure and may be affected by:

• network availability;

• recipient device status;

• operator filtering;

• spam controls;

• channel restrictions;

• sender verification;

• content restrictions; and

• other factors outside Abelo's reasonable control.

Customers must not attempt to circumvent channel restrictions, operator controls, spam filters, sender verification requirements, or other technical safeguards.

7. Prohibited Content and Activities

Customers must not use Abelo to send, facilitate, promote, or distribute content or activity that is unlawful or abusive.

Prohibited use includes, without limitation:

7.1 Illegal Activities

Use of Abelo for activities that violate applicable law or regulation.

7.2 Fraud and Deception

Fraudulent schemes, scams, impersonation, deceptive offers, misleading claims, or other attempts to deceive recipients.

7.3 Phishing and Social Engineering

Phishing, credential theft, impersonation, malicious social engineering, or communications designed to obtain passwords, authentication codes, financial information, or other sensitive information through deception.

7.4 Malware and Malicious Code

Distribution of malware, viruses, ransomware, spyware, malicious scripts, or other harmful code.

7.5 Harassment and Abuse

Threats, harassment, stalking, intimidation, abusive communications, or communications intended to cause unlawful harm.

7.6 Hate and Discriminatory Content

Content that unlawfully promotes hatred, discrimination, or violence against individuals or groups.

7.7 Child Exploitation

Any content or activity involving child sexual exploitation, abuse, or other unlawful exploitation of minors.

7.8 Unlawful Adult Content

Use of Abelo for unlawful pornography, sexual exploitation, or other prohibited sexual content.

7.9 Illegal or Unlicensed Gambling

Use of Abelo to operate, promote, or facilitate unlawful or unlicensed gambling activities.

7.10 Regulated or Restricted Goods

Promotion or sale of illegal or heavily regulated goods or substances where such use is prohibited by applicable law or the relevant messaging provider.

This may include controlled substances, illegal drugs, weapons, or other restricted products.

7.11 Financial Abuse

Use of Abelo for fraudulent financial activity, unauthorized financial services, investment scams, or other unlawful financial schemes.

Legitimate regulated financial institutions and lawful financial communications may use Abelo subject to applicable laws, regulatory requirements, channel policies, and any additional Abelo approval requirements.

7.12 Pyramid Schemes and Fraudulent MLM

Use of Abelo for illegal pyramid schemes or deceptive multi-level marketing activities.

Legitimate businesses may be subject to additional review where their business model presents elevated messaging or regulatory risk.

8. Spam and Unsolicited Communications

Customers must not use Abelo to send spam or unsolicited communications.

Customers must:

• send communications only to appropriate recipients;

• respect applicable consent requirements;

• honor opt-outs promptly;

• maintain accurate suppression lists;

• avoid misleading sender identities;

• avoid excessive messaging frequency;

• use appropriate message categories;

• monitor complaints and delivery performance; and

• take corrective action when recipient complaints increase.

Customers must not purchase, scrape, harvest, or otherwise obtain recipient lists for use through Abelo where doing so is unlawful or violates applicable requirements.

Abelo may review accounts that generate unusually high complaint, block, spam-report, failure, or opt-out rates.

8.1 Permitted Sending Times and Quiet Hours ("Ώρες Κοινής Ησυχίας")

Customers must schedule and dispatch promotional communications only during hours permitted by applicable consumer protection laws, electronic communications directives, and telecommunications operator rules in the recipient's jurisdiction.

In particular, when communicating with recipients in Greece, Customers must strictly observe statutory quiet and resting hours pursuant to Greek consumer protection and telecommunications regulations (including Law 2251/1994, Law 3471/2006, and Hellenic Telecommunications and Post Commission - EETT directives). Customers must not dispatch promotional marketing communications during nighttime hours (22:00 to 08:00 or 09:00) or afternoon quiet hours (15:00 to 17:30). Customers are solely responsible for configuring campaign delivery schedules within the Platform to ensure full compliance with recipient jurisdiction time-of-day restrictions.

9. Sender Identity and Transparency

Customers must not impersonate another individual, business, organization, government authority, brand, or service.

Customers must use accurate and authorized sender identities.

Customers must provide verifiable documentation of corporate identity, trademark ownership, or valid commercial authorization for any requested SMS Alphanumeric Sender ID (up to 11 characters) or Viber Business Sender name. In compliance with carrier regulations and national telecommunications frameworks (such as EETT rules in Greece), Abelo reserves the right to review, reject, or revoke any Sender ID that lacks proof of authorization, mimics third-party brands, or creates a risk of carrier filtering, spoofing, or fraudulent delivery.

Message content must not intentionally conceal the identity of the sender where disclosure is required by applicable law or channel policy.

Customers must not use Abelo to create misleading URLs, sender names, message headers, or other identifiers designed to deceive recipients.

10. Sensitive and High-Risk Communications

Certain industries, business models, content types, and communication use cases may create additional legal, regulatory, security, or reputational risks.

Examples may include:

• financial services;

• healthcare;

• insurance;

• pharmaceuticals;

• gambling;

• political communications;

• government services;

• regulated professional services;

• cryptocurrency and digital assets;

• adult services;

• debt collection; and

• other regulated or sensitive sectors.

Such businesses are not automatically prohibited from using Abelo.

However, Abelo may require additional information, verification, contractual controls, approvals, or restrictions before enabling particular messaging use cases or channels.

11. Data Sources and Contact Lists

Customers must not upload or synchronize:

• purchased contact lists where the relevant use is unlawful;

• scraped contact information;

• illegally obtained personal data;

• data obtained through deceptive means;

• data belonging to individuals without an appropriate legal basis; or

• data that the Customer is prohibited from processing or sharing.

Customers are responsible for ensuring that contact lists and recipient data are accurate and lawfully obtained.

12. Opt-Outs and Suppression

Customers must promptly honor recipient requests to stop receiving promotional communications.

Where Abelo provides suppression or opt-out functionality, Customers must use it appropriately and must not attempt to circumvent suppression mechanisms.

Customers must not re-add a recipient to a promotional campaign after a valid opt-out unless a new lawful basis or permission has been obtained where

required.

13. Technical Integrity and Security

Customers must not:

• attempt to gain unauthorized access to Abelo systems;

• bypass authentication or authorization controls;

• circumvent API or platform rate limits;

• interfere with Platform availability or performance;

• introduce malicious code;

• scan or probe Abelo systems without authorization;

• reverse engineer the Services except where expressly permitted by applicable law;

• scrape data from the Abelo Platform;

• use automated methods to access areas of the Platform not intended for such access;

• attempt to bypass messaging-provider restrictions;

• use compromised credentials or API keys; or

• interfere with the operation of messaging infrastructure.

Customers must protect their account credentials, API keys, access tokens, and other authentication information.

14. API and Automation Use

Customers using Abelo APIs, SDKs, webhooks, or automation functionality must comply with the applicable technical documentation and usage limits.

Customers must not use APIs or automation functionality to:

• generate spam;

• circumvent consent requirements;

• create abusive messaging volumes;

• bypass platform restrictions;

• attack or overload Abelo infrastructure;

• distribute malicious content; or

• perform unauthorized data collection.

Abelo may apply rate limits or other technical restrictions to protect the Platform and messaging infrastructure.

15. Monitoring and Compliance

Abelo may monitor usage of the Services for purposes including:

• security;

• fraud prevention;

• abuse prevention;

• regulatory compliance;

• messaging quality;

• deliverability;

• protection of messaging networks;

• investigation of complaints; and

• enforcement of this AUP.

Where reasonably necessary, Abelo may request information regarding:

• the Customer's business;

• the intended use of the Services;

• message content;

• recipient sources;

• consent or authorization;

• sender identity;

• relevant documentation; or

• regulatory approvals.

Customers must provide accurate information and cooperate with reasonable compliance investigations.

16. Suspension and Enforcement

Where Abelo reasonably believes that a Customer has violated this AUP, applicable law, messaging-provider requirements, or created a material risk to the Services, Abelo may take appropriate action, including:

• requesting additional information;

• rejecting messages;

• restricting campaigns;

• disabling a messaging channel;

• limiting messaging volume;

• suspending specific users;

• suspending an account;

• terminating an account;

• reporting suspected unlawful activity to appropriate authorities; or

• taking other reasonable protective measures.

Abelo may take immediate action where necessary to prevent fraud, abuse, security threats, unlawful activity, significant messaging-provider violations, or material harm to recipients, Abelo, or its messaging partners.

Where reasonably practicable, Abelo will notify the Customer of the reason for a restriction or suspension.

17. Messaging Provider Requirements

Abelo may be required to comply with requirements imposed by messaging networks, telecommunications operators, technology providers, regulators, or other third parties.

Where such requirements apply to a Customer's use of Abelo, the Customer agrees to comply with them.

A messaging provider may independently reject, restrict, suspend, or terminate messaging services.

Abelo is not responsible for restrictions imposed by third-party messaging providers where those restrictions result from the provider's policies, network controls, regulatory obligations, or other circumstances outside Abelo's reasonable control.

18. Regulatory and Legal Requests

Abelo may cooperate with competent authorities and disclose information where required by applicable law, regulation, court order, or valid legal process.

Nothing in this AUP prevents Abelo from taking reasonable action necessary to comply with legal obligations or protect recipients, customers, employees, infrastructure, or third parties.

19. Consequences of Violation

Violations of this AUP may result in suspension or termination of Services.

Where permitted by the applicable Terms of Use or commercial agreement, fees paid for Services affected by a violation may not be refundable.

Additional consequences may apply where the violation causes financial, legal, regulatory, security, or reputational harm to Abelo or third parties.

20. Relationship with Other Abelo Policies

This AUP forms part of the agreement governing use of Abelo.

It should be read together with:

• the Abelo Terms of Use;

• the Abelo Privacy Policy;

• the Abelo Data Processing Agreement;

• applicable service-specific terms; and

• applicable messaging-provider requirements.

If there is a conflict between this AUP and another document governing the Customer’s use of Abelo, the order of precedence set out in the Abelo Terms of Use applies.

21. Changes to This AUP

We may update this AUP from time to time to reflect:

• changes to the Services;

• changes to messaging-provider requirements;

• changes to applicable laws and regulations;

• changes in security standards;

• new types of abuse or threats; or

• changes to our operational practices.

When material changes are made, we will update the "Last Updated" date and, where appropriate, notify Customers through the Platform or by email.

Customers are responsible for reviewing the current version of the AUP.

22. Governing Law and Jurisdiction

This AUP is governed by the laws of Greece and applicable European Union law.

Unless otherwise required by mandatory applicable law, disputes arising from or relating to this AUP shall be subject to the jurisdiction of the competent courts of Athens, Greece.