Owner Services Annex to the DPP Host Terms of Service

Version of 29 October 2026 (2026-10-29.2)

This text is published in English only.

1. Scope and order of precedence

1.1 This annex applies when a brand (the "Brand") turns on the owner services module in the DPP Host dashboard. It supplements the DPP Host Terms of Service between the Brand and Qubites ApS, Ulsøparken 49, 2. tv., 2660 Brøndby Strand, Denmark, CVR 37061026 ("DPP Host", "we").

1.2 If this annex and the Terms of Service conflict on owner services, this annex prevails. On the processing of personal data, the DPA prevails (Schedule 1).

1.3 Danish law governs this annex, as it governs the Terms of Service.

2. Definitions

Owner: a person who uses the Owner Area, whether they have registered an item or not. This includes a person who sends a dispute and a person who asks only for safety alerts (clause 3.12).
Owner Area: the Brand's area at https://app.dpphost.eu/owner/{handle}, where {handle} is a random 12-character value DPP Host assigns.
Owner Data: personal data processed in the Owner Area or about Owners in the Brand's dashboard, API responses and webhooks. Annex I part A of the DPA lists it.
DPA: the DPP Host Data Processing Agreement between the Brand and DPP Host (Schedule 1).
Item: one physical product, identified by its GTIN and serial number (the GS1 path /01/{gtin}/21/{serial}).
Claim Code: a 16-character code the Brand issues for one Item, which lets the person who has it register that Item. It comes with a claim link (clause 3.13).
Handover Code: a 12-character code a registered Owner creates to pass their registration to the next Owner at a distance. It works once, for 24 hours, and completes a handover only together with the seller's 4-digit number (clause 3.9).
Registration: the record that an Owner is the registered owner of an Item. It is not a record of legal title.
Offer: a link the Brand configures, labelled as coming from the Brand or from a named partner (a "Partner"), for an extended warranty, insurance, repair or another service.
Premium: the Premium Plan (Terms of Service clause 5.1), which includes owner services.
Shop: a business with its own DPP Host organisation that the Brand has linked, under the Retailer Terms, to hand the Brand's products and their Registrations to its customers (clause 3.14).

3. What DPP Host provides

3.1 On the passport. While the module is live (clause 4.2), every published passport of the Brand shows a separate card "Own this product?", run by DPP Host for the Brand, that links to the Owner Area to register the product and, on a passport with a GTIN, to ask only for safety alerts (clause 3.12) or to take the product over from its registered Owner (clause 3.9). The card sits outside the regulated passport content. The passport itself stays anonymous and needs no sign-in. No passport page, passport data, passport or page file in R2, integrity timestamp or blockchain holds or shows anything about Owners. With the module on, the resolver answers the GS1 link types gs1:registerProduct and gs1:support with a redirect to the Owner Area.

3.2 In the Owner Area, DPP Host lets an Owner:

sign in with a one-time code or link sent by email (no password), or continue with Apple or Google (clause 3.8). The code and the link are valid for 15 minutes;
open an owner account with the Brand. Accounts are scoped to one Brand; there is no cross-brand view;
register an Item with a Claim Code or its claim link (clause 3.13). A registration can be disputed for 14 days, or for the period of 0 to 30 days that DPP Host has set for the Brand (the "dispute period");
send the Brand a dispute note when a code was already used;
record the purchase date (and, optionally, where the Item was bought) and see the legal guarantee and the Brand's commercial guarantee side by side;
send a repair request or a guarantee claim, each of up to 2,000 characters;
see the Brand's Offers;
hand an Item over to the next Owner, face to face or at a distance, and take an Item over from another Owner or from a Shop (clauses 3.9 and 3.14);
make a view-only proof of registration link (clause 3.10);
add a registered Item to Apple Wallet (clause 3.11);
choose the address to which the Brand's safety notices for an Item are sent (clause 3.12);
record which of the Brand's batteries is fitted to which of its e-bikes (clause 3.15);
mark an Item lost or stolen, and lift that mark;
end their registration ("I no longer have it");
give or withdraw consent to marketing emails from the Brand;
turn on or off, per registered Item, the care reminders the Brand configured, by email; withdraw with one click from the link in each reminder;
prepare a resale listing for an Item (the Brand's own resale or take-back programme first; then a text with the product, its size, the published materials and the passport's address, and plain links to the create-listing pages of Vinted, Facebook Marketplace, eBay and DBA). DPP Host sends nothing to those sites;
download their account, their name for the cards, consents, registrations, purchase records, requests, separate safety addresses, wallet cards, open proof links and the item-log entries linked to them as JSON, and delete their account.

3.3 In the dashboard (Organisation → Owner services), DPP Host lets the Brand configure the module (settings, commercial guarantees, Offers, care reminders), issue Claim Codes (on screen or from a CSV file), look up Items, mark or unmark Items, release Registrations, handle repair requests, guarantee claims and disputes in an inbox that shows the Owner's email address and message, see registrations per product, and (admins) export them as a file in which only Owners who agreed to hear from the Brand appear with their contact details (clause 5.8.2). It also lets the Brand print Claim Codes as cards and email a registration link to a customer (clause 3.13), prepare and publish safety notices and see how many safety contacts each product has (clause 3.12), and invite, change and remove Shops (clause 3.14).

3.4 API and webhooks. Under the scopes owners:read and owners:write (Premium, editor role or higher), the Brand's systems can issue Claim Codes with their claim links, release Registrations and read a repair request or dispute. Webhooks owner.claimed, owner.transferred, owner.returned, warranty.registered and repair.requested (with the request's kind: a repair or a guarantee claim) go to endpoints the Brand configures. They carry ids, references, the Item (GTIN, serial, resolver path), the event and its time, and for a Shop's handover or return the Shop's name, never an email address, a message, a purchase date or a place of purchase. Because the Brand can link a serial to its own sales records, they are pseudonymous Owner Data (DPA Annex I A.7). The webhook safety_notice.published carries the notice and the products, batches and serial numbers it concerns, never an address or a count of people.

3.5 Emails. DPP Host sends, for the Brand and from DPP Host's address: the Owner's sign-in and address-confirmation emails; the care reminders an Owner turned on for an Item (clause 5.10); the Brand's safety notices and the confirmation of a separate safety address (clause 3.12); a registration link the Brand asks it to email (clause 3.13); and the link of a Shop's handover that the Shop asks it to email (clause 3.14). The Brand's admins get an email for each repair request and guarantee claim, naming the product, serial number and reference only (pseudonymous Owner Data, as for webhooks). DPP Host sends no other email to Owners, and no marketing. Registration confirmations, handover notices and replies to repair requests are not part of the service; the Brand answers Owners from its own systems. Emails to Owners contain no tracking pixel and no tracked link.

3.6 What DPP Host does not do. DPP Host:

does not sell, price, recommend or arrange any Offer, and adds nothing about the Owner to an Offer's link;
keeps no public register of stolen items and offers no public ownership lookup. A proof of registration link (clause 3.10) shows only what the Owner chooses to share;
does not decide who legally owns an Item. The Owner Area records registrations, not legal title (clause 6);
does not decide disputes, guarantee claims or repair requests;
does not sync with the Brand's own shop. The Brand issues and releases codes itself or through the API. A Shop the Brand linked hands products over through DPP Host (clause 3.14);
does not export Owners who have not agreed to hear from the Brand: they appear in the registrations export only as a count per product and size (clause 5.8.2);
does not list Items on any resale platform, call any platform's interface or receive anything from one (the listing helper only prepares a text the Owner copies).

3.7 Features not included. Item tokens held in the Owner's own wallet, "sign in with your wallet" and sponsored transactions are not part of this annex. They would be offered only under an amended annex and an addendum to the DPA (Annex I part B, Annex III part 3), after further steps that include a DPIA and a legal opinion.

3.8 Sign-in with Apple or Google, and the Owner's name. Beside the email code or link, the Owner Area offers "Continue with Apple" and "Continue with Google". The short privacy notice tells the Owner that DPP Host is itself responsible for the sign-in (Schedule 4). With Apple or Google, the sign-in also holds the Owner's identifier at that provider and the name and email address the provider shares. A provider sign-in with the email address an Owner registered under opens the same owner accounts. An Owner who hides their address with Apple signs in with a relay address, which opens a separate owner account without the Items registered under their own address. A sign-in gives no access to the Brand's organisation in the dashboard. The Owner may give a name for their cards, of up to 60 characters. It starts from the name Apple or Google shares, never from the email address, and the Owner can change or remove it. The Owner's own product page and wallet card show it in full; the other side of a handover sees only the first name and the initial of the last name; a proof of registration link shows the initials, or the full name if the Owner chooses. The Brand never sees an Owner's name.

3.9 Handing an Item over. A registered Owner hands the Registration to the next Owner in one of two ways. A Handover Code alone does not complete a handover.

Face to face: the seller's product page shows a QR code that changes every few seconds. The buyer scans it, sees the product and that it is ready to hand over, signs in and asks to take it over. The seller then sees the buyer's first name and initial and how the buyer signed in (Apple, Google or an email code), and has 10 minutes to hand the Item over or turn the buyer down.
At a distance: the seller sends the buyer a Handover Code, or a link that carries it. The buyer enters it, signed in, and can check the product before paying. When the buyer asks for it, the seller's page shows a 4-digit number for 10 minutes, which the seller gives the buyer. The right number completes the handover; the third wrong number cancels it. The seller can cancel the handover at any time ("Not my buyer").

Before taking over, the buyer sees the product, the seller's first name and initial, since when the seller has had it, and how many of the Brand's published safety notices concern it. Every case in which an Item cannot be handed over (an unknown, expired, used or cancelled code, or an Item marked lost or stolen) gets the same answer: "This product can't be handed over. Contact {Brand}." No handover can start while the Item is marked lost or stolen or while its Registration is within the dispute period. On completion the seller's Registration ends, the buyer's starts without a dispute period, the seller's wallet cards say that the Item is no longer registered to them, and the webhook owner.transferred is sent. The item log records each step. It shows that both sides took part, not that the Item was delivered or who owns it in law (clause 6).

3.10 Proof of registration. The Owner can make a view-only link, with its QR code, for example for a buyer or an insurer. It shows the product, its size, serial number and batch, since when it has been registered with the Brand, the time DPP Host checked it and, where the Owner has given a name, the initials or, if the Owner chooses, the full name. It states that it is not proof of legal ownership, and never shows an email address. It works for 24 hours, until the Owner withdraws it or makes a new one, and stops working when the Registration ends, when the Item is marked lost or stolen or while the module is paused. The Owner sees how often it was opened. Nothing about the person who opens it is kept.

3.11 Wallet cards. While the module is live, an Owner can add a registered Item to Apple Wallet. The card shows the Brand, the product, its serial number and batch, the Owner's name for the card, since when the Item is registered, the guarantee's estimated end once a purchase date is recorded, a lost or stolen mark, the Brand's published safety notices for the Item and the QR code of its passport; for an e-bike, its fitted battery, and for a battery, the product it is fitted to; and, after a Shop's handover, "Bought at {Shop}" (clause 3.14). It states that it shows the Registration and is not proof of legal ownership. It never shows an email address, a Claim Code or a Handover Code; while a buyer at a distance waits, the seller's card shows the buyer's first name and initial and the seller's 4-digit number until the number stops working. When what the card shows changes, DPP Host tells the Owner's devices through Apple's push service, which receives only each device's push token and an empty message; after a handover, a release or a return, the card says that the Item is no longer registered to the Owner. Apple keeps the card on the Owner's devices under the Owner's own terms with Apple. The Brand sees no card, device or count of cards.

3.12 Safety notices and safety contacts. The Brand's editors prepare safety notices (warnings and recalls) for its products, for all or chosen sizes, batches and serial numbers, and an admin, freshly signed in, publishes and closes them. A published notice shows on the passport pages it concerns, on every Plan. While the module is live, the Brand can also have DPP Host email it to the registered Owners of the Items it concerns and to safety contacts. A safety contact is a person who asked, from a passport page, for the Brand's safety alerts for an Item without opening an owner account, or a registered Owner who gave a separate address for safety alerts and confirmed it by a link. Registered Owners get the Brand's safety notices while their Registration is active; a safety contact stops them with the one-click link in each email. A safety contact's address is used only for the Brand's safety notices for that Item (Regulation (EU) 2023/988, Art. 35(2)), never for marketing. The Brand sees, per product, how many safety contacts it has and, per notice, how many addresses it reaches, each as a number from 5 or "fewer than 5". It never sees or exports a safety contact's address, a registered Owner's separate safety address included.

3.13 Claim links and registration links. Each Claim Code comes with a claim link that opens the Owner Area with the Item and the code filled in; the code sits in the part of the link that a browser does not send to a server. The Brand can print its Claim Codes as cards for the box, put the claim link in its own order email through the API, or, while the module is live, have DPP Host email the link once to a customer (editors, in the dashboard, at most 200 a day). The customer's address is kept only in the record of that email, and no member sees it after the email is sent.

3.14 Shops' handovers. While the module is live, the Brand's admin, freshly signed in, can invite a shop to hand the Brand's products and their Registrations to its customers, for all or chosen products, and can change that or remove the Shop at any time. The Shop has its own DPP Host organisation and accepts the Retailer Terms. Its members (editor role or higher), its API keys with the scope handovers:write and its web shop's connection to DPP Host hand over 1 to 10 of the Brand's Items at a time: at the counter, with a QR code the customer scans and the Shop's staff confirm, or with a one-time link, valid for 30 days, that DPP Host emails to the customer at the Shop's request or that the Shop gives the customer itself. A Shop can also print a link on its own invoices, with which its customer registers a product bought there. The customer signs in and takes the Items over. Each Registration starts at once, with no dispute period. It records the day of sale as the purchase date and the Shop as the place of purchase, with the commercial guarantee configured at that time (clause 5.2.3), and the Item's unused Claim Code is revoked. The Owner's product page and wallet card say "Bought at {Shop}" while that Registration is active. The Shop sees the products, serial numbers, state and times of its handovers, and the customer's first name and initial until 30 days after the handover ended; it never sees an Owner otherwise. A Shop can undo its own handover within 30 days when the product came back to it: the Registration ends, and the Brand gets the webhook owner.returned. The Brand sees these Registrations with the Shop's name.

3.15 E-bikes and their batteries. For the Brand's e-bikes and batteries registered to the same Owner, the Owner Area records which battery is fitted to which e-bike: from a Shop's handover, from the box card's Claim Code, from the Owner's own entry, from a Shop's workshop or with a handover between Owners. Each wallet card then names the other part. When the Owner hands over or marks an e-bike, they choose whether its fitted batteries go with it; a built-in battery always does. A Shop can replace an e-bike's battery at its workshop: the new battery is registered to the Owner and fitted, and the old battery's Registration ends. This record is the Owner's own note: the Brand does not see it.

3.16 Built, not available yet. The following are built but not available to Brands yet, and are not part of the service today:

receipts: a Shop adds the customer's receipt to its handover, and the customer chooses at the take-over whether it is kept with the Registration. Only the Owner sees, downloads or removes it. The Owner may attach it to a repair request or guarantee claim; the Brand is then told that a receipt is attached, and cannot download it;
messages from finders: while an Owner has marked an Item lost or stolen and lets finders message them, the Item's passport page says that its owner is looking for it, and a finder can send the Owner a message that only the Owner sees;
Google Wallet cards.

4. Availability

4.1 Owner services are part of Premium. See clause 10 for fees.

4.2 The module is live only while all three hold: the Brand has turned it on (admins only), the Brand is on Premium, and the Brand's organisation is neither read-only nor archived.

4.3 While the module is not live but has been set up (paused), the owner card leaves the passport, and new claims, handovers (a Shop's included), registrations, disputes and requests stop. Offers are no longer shown. Proof of registration links stop working, no new wallet cards are issued, and registration links, care reminders and the emailing of safety notices stop; a published safety notice still shows on the passport pages. Owners can still sign in, see their Items, download their data and delete their account. Nothing is deleted because of the pause.

5. The Brand's responsibilities

5.1 The Brand as controller

5.1.1 The Brand is the controller of Owner Data (GDPR Art. 4(7)). It decides to run the module, which services and Offers exist, and what happens to requests. DPP Host processes Owner Data only as the Brand's processor, under the DPA (Schedule 1).

5.1.2 Before it turns the module on, the Brand shall:

publish a privacy notice that meets GDPR Art. 13 and enter its https address in the settings. The Owner Area links to it under "Privacy notice of {Brand}". DPP Host provides a template on request but is not responsible for the Brand's notice;
enter a support email address that it monitors;
have an admin accept this annex and the DPA in the dashboard (Organisation → Owner services); DPP Host records the version, the time and the admin. The module cannot be turned on without the privacy-notice link, the support address and this acceptance, and while it is on neither the link nor the address can be removed;
record the processing in its records of processing activities (Art. 30);
decide whether a data protection impact assessment is required (Art. 35) and, if so, carry it out. DPP Host helps under DPA clause 10.

5.1.3 The Brand shall have, and keep, its own terms of use for Owners, which the Owner accepts when opening an account. They are the contract that makes Art. 6(1)(b) the legal basis for providing the services.

5.1.4 Owners exercise access, portability and erasure themselves in the Owner Area. Rectification, restriction and objection go to the Brand. DPP Host helps under DPA clause 9.

5.2 Guarantees

5.2.1 The legal guarantee. The Owner Area shows a fixed text on the seller's liability under Directive (EU) 2019/771 (Art. 10: the seller is liable for any lack of conformity which exists at the time of delivery and becomes apparent within two years of that time, or longer where national law provides). The Brand cannot change that text. The text is set out in Schedule 4. The Brand shall not, anywhere in the Owner Area, in its commercial guarantee terms or in an Offer:

say or suggest that the legal guarantee depends on registration, on the commercial guarantee, on buying an Offer or on using the Brand's repair service;
present the legal guarantee as a feature of its own offer (Directive 2005/29/EC, Annex I, point 10);
describe an extended warranty or insurance in a way that misleads the consumer about the rights they already have under the legal guarantee (Arts. 6 and 7 of Directive 2005/29/EC, as amended by Directive (EU) 2024/825).

5.2.2 The commercial guarantee. Where the Brand configures a commercial guarantee, it is responsible for making it meet Art. 17 of Directive (EU) 2019/771. In particular:

the guarantee statement must give the guarantor's name and address, the procedure the consumer follows to use it, the goods it applies to and its terms, and state clearly that the consumer is entitled by law to free remedies from the seller for lack of conformity, which the commercial guarantee does not affect (Art. 17(2)). The Owner Area shows what the Brand enters: the guarantor's name and address, the duration, the terms per language and a link to the full terms, and the fixed line "To claim under this guarantee, follow {Brand}'s terms or contact {Brand}: {support address}". A commercial guarantee cannot be saved without the guarantor's name and address, and one saved without them is not shown. The Brand shall make sure these fields contain all of the above, including the procedure;
the guarantor is bound by the conditions in the guarantee statement and in associated advertising, and the more advantageous of the two applies (Art. 17(1)). What the Brand writes in the Owner Area and in its Offers counts as advertising;
where the Brand, as producer, offers a commercial guarantee of durability, it is directly liable to the consumer for repair or replacement for the whole period (Art. 17(1), second subparagraph);
the guarantee statement must reach the consumer on a durable medium at the latest when the goods are delivered (Art. 17(2)). The Owner Area does not replace that step;
the Brand shall say in its terms whether the commercial guarantee passes to a later owner. The Owner Area asks each new Owner to record the purchase again and does not carry the earlier Owner's registration over;
the Brand shall follow any harmonised notice or label rules that apply to it under the Consumer Rights Directive as amended by Directive (EU) 2024/825.

5.2.3 The Owner Area calculates the estimated end date of a commercial guarantee from the purchase date the Owner enters and the duration the Brand had configured when the Owner first saved a date for that Registration. If the Owner corrects the date after the Brand has changed its guarantee, the first saved duration stays; a Registration saved while no guarantee was configured takes the duration configured when the date is next saved. The Owner Area shows the saved duration once there is one, and labels the end date as an estimate. The Owner can record or correct the date only while the module is live. It does not verify the purchase date. The Brand decides whether a claim is covered.

5.2.4 Fixed texts. The Owner Area shows texts that DPP Host writes and the Brand cannot change: the legal-guarantee text, the duration and estimated end date of the commercial guarantee, the text shown where no commercial guarantee is configured, the offers notice and the short privacy notice (Schedule 4). Before it turns the module on, the Brand reviews them and adopts them as its own information to Owners; the acceptance of this annex in the dashboard (clause 5.1.2) records that adoption for the versions current at that time. DPP Host provides them as part of the service. It gives Owners no guarantee, advice or information on its own behalf. If a fixed text does not fit the Brand's terms or the law of a country where it sells, the Brand tells DPP Host at once, and may keep the module off until the text is changed.

5.3 Guarantee claims and repair requests

5.3.1 The Brand handles every repair request and guarantee claim itself, answers the Owner by email from its own systems, and sets each request's status in the inbox. DPP Host is not a party to any guarantee, repair or sale.

5.3.2 Where the Brand is not the seller, it shall tell Owners who ask about the legal guarantee that their claim is against the seller.

5.3.3 The Brand shall close requests once handled. Retention of request texts runs from closing (DPA Annex I A.6). An open request keeps its text until it is closed or the Owner's account is deleted, by the Owner or by the idle-account rule.

5.4 The Brand's own consumer-law duties

5.4.1 Owner services do not replace any of the Brand's duties towards consumers, including information before the contract and the right of withdrawal under the Consumer Rights Directive 2011/83/EU (Arts. 6, 9 to 16), and remedies under Directive (EU) 2019/771.

5.4.2 When an Item is returned, whether on withdrawal, on termination for lack of conformity, or under the Brand's own return policy, the Brand shall release its Registration (dashboard, or POST /v1/owner-items/release, for example from its shop's refund webhook) and issue a new Claim Code before selling it again. Releasing also cancels any open Handover Code.

5.4.3 The Brand decides disputes fairly and on the evidence (for example proof of purchase). The Owner Area tells neither side who the other is. The Brand's editors and admins see both email addresses: the registered Owner's on the Item and the disputer's on the request. The Brand shall not reveal one Owner's identity to the other without a legal basis.

5.5 Claim codes

5.5.1 The Brand issues Claim Codes only for Items it has made or sells under its own GTINs, and is responsible for the GTIN and serial being correct.

5.5.2 Codes are shown once, when issued (on screen or in the API answer), and DPP Host keeps only a keyed hash (HMAC-SHA-256 with a secret that, in production, is held in Supabase Vault) and the last four characters. DPP Host cannot show a code again. The Brand shall:

store and transmit codes securely until they reach the buyer, and never publish them;
give each code only to the buyer of the Item it belongs to: printed hidden in the care label, in the packaging, or in the order confirmation;
issue a new code if a code may have leaked (a new code revokes the unused one).

5.5.3 An Item with a registered Owner gets no new code until the Registration ends.

5.6 Lost and stolen marks

5.6.1 A mark the Brand sets stays until the Brand lifts it; the Owner cannot lift it. The Brand shall set a mark only when it has a reasonable basis to believe the Item is lost or stolen (for example the registered Owner told it so), shall lift it when that is no longer the case, and shall not use marks to prevent lawful resale.

5.6.2 The Brand shall not collect police reports or other data on criminal offences in connection with a mark (GDPR Art. 10). The Owner Area has no field for them.

5.6.3 The Brand can also lift a mark that the Owner set. If the Brand marks an Item that the Owner has already marked, the Brand's mark replaces the Owner's, and the Owner can no longer lift it. The Brand shall lift or replace an Owner's mark only at that Owner's request, or where it has a reasonable basis under clause 5.6.1, and shall record the reason.

5.7 Offers

5.7.1 For each Offer, the Brand or the named Partner is the provider and seller. The Brand is responsible for the Offer's content, title, link and terms, and for the Offer being lawful, including under consumer protection and unfair commercial practices law.

5.7.2 Insurance. Where an Offer is for insurance, or for an extended warranty that is insurance under the applicable law, the Brand and the Partner are responsible for compliance with Directive (EU) 2016/97 on insurance distribution (IDD) and its national implementation. That includes any registration as an insurance or ancillary insurance intermediary, or reliance on the exemption in Art. 1(3), and the information and conduct rules towards the customer. The Brand warrants that it and each Partner meet these rules.

5.7.3 DPP Host's role for Offers. DPP Host only displays the link and label the Brand configures. It gives no advice, makes no comparison or ranking, takes no premium and takes no further steps to help conclude or perform an insurance contract. The parties intend this to be no more than the provision of information about insurance products under Art. 2(2)(d) IDD, and agree that DPP Host will not act as an insurance intermediary. DPP Host receives no commission, fee or other remuneration linked to insurance sales, clicks or leads. Any such arrangement would need a separate written agreement and only if it is lawful for DPP Host at that time (which may require DPP Host to register). The Brand shall not describe DPP Host as the provider, adviser or intermediary of any Offer. The Owner Area states that the offers come from the Brand or its partners, not from DPP Host, and that DPP Host does not sell or price them, and shows the host of each link.

5.7.4 Offers are configured per organisation or per product, never per Owner. The Brand shall not put anything into an Offer link that identifies an Owner. It may add general campaign parameters.

5.7.5 A Partner that receives an Owner's data when the Owner follows an Offer link receives it directly from the Owner, as a separate controller. DPP Host does not pass Owner Data to Partners.

5.8.1 The Owner Area asks for marketing consent separately from the account, with an unticked box, and records each change (granted or withdrawn, time, text version and language). The Brand may send marketing to an Owner by email only while that Owner's most recent consent is "granted", and within what the consent text says (GDPR Arts. 6(1)(a) and 7; Directive 2002/58/EC Art. 13; in Denmark, markedsføringsloven § 10). DPP Host keeps the wording of each consent text version in every language, never changes it, and gives it to the Brand on request; each consent record names the text version and language it was given on, and the Owner's export shows the text. The Brand approves the marketing consent wording before it turns the module on (clause 5.2.4).

5.8.2 The Brand's admins can export the active Registrations (Owner services → Registrations). Owners whose most recent marketing consent is "granted" appear with the serial number, the registration date, their email address, their language and the date of that consent; every other Registration appears only in a count per product and size, written "<5" when it is under 5. The dashboard shows the counts of Registrations and Owners under 5, zero included where they concern Owners, as "fewer than 5". Each export is recorded in the Brand's action log. The Brand sees each registered Owner's current consent in the Items tab. Before each campaign the Brand shall export again or check the current state, and remove Owners who have withdrawn from its own lists. The Brand is responsible for honouring withdrawals in its own systems, and for the data it takes out of DPP Host (clause 5.9.3).

5.8.3 The Brand shall not use repair requests, dispute notes, purchase dates or Registrations for marketing or profiling beyond what its privacy notice states and its legal basis allows.

5.9 Settings and staff

5.9.1 The Brand is responsible for the accuracy of what it enters: the name shown to Owners, the privacy notice link, the support address, guarantor details, guarantee terms and Offers.

5.9.2 Owners' email addresses, marketing choices, places of purchase and requests are visible in the dashboard to members with the editor or admin role (the requests inbox and the Owner's email address on an Item), and through the API to keys with owners:read (GET /v1/owner-requests/{id} returns the requester's email address and message). Members with the viewer role see registration status and dates, purchase dates and guarantee months, marks, claim-code status and the item log, which the Brand can link to customers through its sales records (DPA Annex I A.5). No member sees an Owner's name, a safety contact's address, a customer's address once a registration link was sent, a wallet card, or which battery is fitted to which e-bike. The Brand decides who gets those roles and keys, and keeps them to staff who need them.

5.9.3 The Brand is responsible for the systems that receive its webhooks and API answers, and for its own processing of Owner Data it takes out of DPP Host.

5.10 Care reminders

5.10.1 The Brand may configure care reminders: a short text per language and a timing (every year on the first day of a month, or every given number of months after the Registration), for one product, a category or all its products. DPP Host emails a reminder only to an Owner who turned reminders on for that Item, only while the Registration is active and the module is live, and never after the Owner turned them off. Turning them on records the Owner's consent with its time, text version and language; turning them off, in the Owner Area or with the one-click link in each email, records the withdrawal.

5.10.2 The Brand shall use care reminders only for the care, maintenance and safe use of the Item. They shall not promote products or services (including the Brand's own), and shall not be used to measure or profile Owners.

5.10.3 The Brand is responsible for the content of its reminder texts, as for its Offers (clause 5.7.1).

6. Acceptable use

In addition to the acceptable-use rules of the Terms of Service, the Brand shall not:

use the Owner Area for products that are not its own or that it is not entitled to service;
configure Offers that are illegal, misleading, or unrelated to the Item or its care, repair, protection or resale;
ask Owners, in Offers, guarantee terms or anywhere else in the Owner Area, for special categories of personal data (Art. 9) or data on criminal offences (Art. 10);
try to identify Owners from anonymised data, or the other party in a dispute, or link Owners across brands;
guess or harvest Claim Codes or Handover Codes, or test codes it did not issue;
present a Registration as proof of legal ownership;
use owner services to send DPP Host personal data that the service does not need.

DPP Host may remove or disable an Offer or other content in the Owner Area that breaks this clause or the law. It follows its notice-and-action process under the Digital Services Act (Regulation (EU) 2022/2065, Arts. 16 and 17; see the DSA page) and gives the Brand a statement of reasons.

7. Security incidents and codes

7.1 DPP Host tells the Brand without undue delay after it becomes aware of a personal data breach affecting Owner Data (DPA clause 11).

7.2 The Brand tells DPP Host without undue delay if it believes Claim Codes it holds have leaked, so that both parties can decide whether to reissue.

8. Suspension and pausing

8.1 Owner services pause automatically as described in clause 4.3 when Premium ends, when the Brand turns the module off, or when the organisation becomes read-only or archived (including a read-only decision under the DSA process).

8.2 DPP Host may also pause the module, or disable a specific Offer, after telling the Brand in writing and giving it a reasonable time to fix the problem, where the Brand seriously or repeatedly breaks this annex. It may act without prior notice where that is needed to stop an ongoing breach of law, harm to Owners, or a security risk. DPP Host gives reasons and restores the module when the reason ends.

8.3 A pause never removes an Owner's access to their data, to the download and to account deletion.

9. End of owner services

9.1 Premium ends, agreement continues. Nothing is deleted. The module stays paused, Owners keep access, the retention rules in DPA Annex I A.6 keep running, and DPP Host keeps processing Owner Data as processor for as long as the Owner Area holds it. When the Brand returns to Premium, the module can go live again.

9.2 Export. At any time during the agreement and for 30 days after it ends, the Brand may ask for an export of all Owner Data (Items, Registrations, guarantee registrations, requests, consents and the item log) in JSON or CSV. In this version the export is prepared by DPP Host on request, not in the dashboard. DPP Host delivers it within 30 days of the request, through a secure channel.

9.3 Agreement ends. Unless the Brand instructs otherwise in writing before the end date, DPP Host:

keeps the Owner Area open, paused, for 90 days after the end, so that Owners can download or delete their data. The Brand tells its Owners this;
then deletes all Owner Data, and confirms the deletion to the Brand in writing.

The Brand may instead instruct DPP Host to return the data (clause 9.2) and delete it at once, or to delete it at once without return (GDPR Art. 28(3)(g)). Deleted data leaves DPP Host's database backups within 7 days, when they are overwritten. DPP Host keeps Owner Data beyond these periods only where EU or Member State law requires it. This clause and DPA clause 12.2 say the same; if they ever differ, the DPA prevails.

9.4 Records that contain no personal data (anonymised item log entries, reference numbers without text, the fact that a claim code was issued) may be kept for as long as the Brand's passport records are kept.

10. Fees

10.1 Owner services are included in the Premium fees in the Brand's order or DPP Host's price list in force. DPP Host may make owner services a separately priced module. It will give at least 90 days' written notice before that applies to the Brand, and the Brand may turn the module off before then without charge.

10.2 DPP Host charges nothing to Owners and takes no fee, commission or share of revenue from Offers (clause 5.7.3).

11. Liability

11.1 The Brand is responsible towards Owners, and towards DPP Host, for its guarantee terms, its handling of claims, disputes and requests, its Offers and Partners, its marks, its marketing, and its privacy notice, and the fixed texts it adopted under clause 5.2.4, except where DPP Host changed them without the Brand's approval. The Brand shall hold DPP Host harmless from third-party claims and fines that result from these, except to the extent DPP Host caused them by breaking this annex or the DPA.

11.2 Each party's liability under Art. 82 GDPR towards Owners is unaffected by this annex. Between the parties, the limitations in the Terms of Service apply.

12. Changes

DPP Host may change this annex with 30 days' written notice, or 90 days' notice where a change reduces what the Brand gets. A change of sub-processors follows DPA clause 7. A change required by law may take effect sooner, and DPP Host explains why. If the Brand does not accept a change to the processing terms, it may turn owner services off and end this annex, without charge, before the change takes effect.

Schedule 1: Processing of Owner Data

DPP Host processes Owner Data as the Brand's processor under the DPP Host Data Processing Agreement (the "DPA"). Annex I part A of the DPA describes the processing, Annex II the security measures and Annex III the sub-processors. If this annex and the DPA conflict on the processing of personal data, the DPA prevails.

Schedules 2 and 3: not used

These schedule numbers are not used: the security measures are in Annex II and the sub-processors in Annex III of the Data Processing Agreement, and the current sub-processors are also on the list of sub-processors.

Schedule 4: Fixed texts (clause 5.2.4)

The texts DPP Host writes and the Brand cannot change, shown to Owners in each language of the Owner Area. The Brand adopts them under clause 5.2.4.

Text	What it includes
Legal guarantee	Its title and its text on the seller's liability (clause 5.2.1)
Commercial guarantee	The title, the duration, the estimated end date and the line naming the guarantor
No commercial guarantee configured	The text shown where the Brand has configured no commercial guarantee
How to claim	The line on how to claim under the commercial guarantee, with the Brand's support address
Purchase date and place of purchase	The labels of the two fields
Offers	The offers notice and the labels of Offers: from the Brand, from a Partner, insurance, and the kind of Offer
Opening an account and marketing consent	The statement shown on opening an account (not a consent), the marketing consent, and the texts for turning marketing emails on and off
Care reminders	The consent, the Owner Area's texts on reminders, the page for turning them off, and the reminder email with its lines on why the Owner gets it and whom to contact
Listing helper	Its texts (clause 3.2)
Short privacy notice (first layer)	The notice and the line naming the Brand as controller and DPP Host as processor. It states that DPP Host is itself responsible for the sign-in, by email or with Apple or Google
Repair requests and guarantee claims	The titles, the hint and the choice between a repair and a claim under the guarantee
Lost or stolen	The explanation and the texts for marks set by the Owner or by the Brand. Where the Brand has no support address (settings saved before it was required), these texts name DPP Host's data protection address (privacy@dpphost.eu), which passes the message on

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