Legal

General Terms and Conditions

Version 2.0 — in force from 9 August 2026

1. Introduction and Scope

1.1 These General Terms and Conditions (the Terms) govern (a) the use of the website alaxona.com (the Site), and (b) every lease of IP Resources by Alaxona to a Customer, including the related pre-contractual relations.

1.2 Alaxona, "we", "us" means Alaxona, established in the Republic of Seychelles, acting as lessor and as the party controlling the leased IP Resources.

1.3 Alaxona leases IP Resources directly, as their holder or as the party authorised by their holder. Alaxona does not operate a marketplace, does not act as an agent or broker of any third party towards the Customer, and is the Customer's sole contractual counterparty under a Lease.

1.4 In the event of conflict, the order of precedence is: (i) the Order; (ii) these Terms; (iii) the Acceptable Use Policy in Schedule 1 (the AUP) and any other policy referenced in these Terms. The AUP forms an integral part of these Terms.

1.5 These Terms are drawn up in English. The English version is authoritative; any translation is for convenience only.

2. Definitions

The following definitions apply throughout these Terms:

• Business Day means any day other than Saturday, Sunday or a public holiday in the Republic of Seychelles.
• Commencement Date means the date on which the Lease term begins: unless the Order states otherwise, the date on which Alaxona has confirmed the Order and received the first payment in full.
• Customer means the legal entity or sole trader identified in the Order that leases IP Resources from Alaxona.
• Daily Rate means the Fees for the relevant billing period divided by the number of days in that period.
• Delivery has the meaning given in Section 6.2.
• Fees means all amounts payable by the Customer under the Order and these Terms.
• IP Resources means IPv4 address blocks allocated or assigned within the RIPE NCC service region and, where expressly agreed, related resources (such as reverse DNS delegations) made available by Alaxona under a Lease.
• Lease means the individual lease contract for specified IP Resources formed under Section 5, consisting of the Order and these Terms.
• Leased Prefix means the IPv4 prefix (or prefixes) identified in the Order.
• MNT-BY Record means the maintainer attribute recorded in the RIPE Database against the object(s) for the Leased Prefix, naming a maintainer designated by the Customer.
• Order means Alaxona's written or electronic offer identifying the Leased Prefix, Fees, term and other commercial parameters, as accepted by the Customer.
• RIPE Database means the public registry database operated by RIPE NCC; RIPE NCC means Réseaux IP Européens Network Coordination Centre; RIR means a Regional Internet Registry.
• Sanctions has the meaning given in Section 23.1.
• Spam has the meaning given in Schedule 1, clause S2.1.

3. Acceptance; Business Customers Only

3.1 These Terms become binding on the Customer upon the earliest of: (a) the Customer's express acceptance in text form (including email or a checkbox on the Site); (b) the Customer's acceptance of an Order that references these Terms; or (c) the Customer's first use of any Leased Prefix.

3.2 Alaxona contracts exclusively with legal entities and sole traders acting in the course of business. Consumer protection laws do not apply. By accepting these Terms the person acting for the Customer represents that they are lawfully able to enter into contracts and have authority to bind the Customer.

3.3 The Customer shall ensure that all information provided to Alaxona is accurate, complete and current, and shall promptly notify Alaxona of any change.

4. Customer Verification and Ongoing Compliance

4.1 Before concluding a Lease, and at any time during it, Alaxona may verify the Customer, including: legal existence and good standing; identity and authority of representatives; beneficial ownership; and screening against Sanctions lists. The Customer shall cooperate with all reasonable verification requests and provide requested documentation without undue delay.

4.2 Alaxona may decline to conclude, or may suspend the conclusion of, any Lease if verification is incomplete, reveals an unacceptable level of risk, or if the Customer or its beneficial owners appear on any Sanctions list.

4.3 Enquiries, correspondence and completed verification do not oblige Alaxona to conclude a Lease.

4.4 Alaxona may retain verification records for as long as required by applicable law and its legitimate compliance interests.

4.5 The Customer shall notify Alaxona in text form within ten (10) Business Days of: (a) any change of direct or indirect control over the Customer (50% or more of voting rights or equivalent); (b) any change of beneficial ownership relevant to Sanctions screening; (c) the commencement of insolvency, liquidation or analogous proceedings affecting the Customer.

4.6 Following a notification under Section 4.5 (or where Alaxona otherwise learns of such a change), Alaxona may re-run verification. If the changed circumstances would have entitled Alaxona to decline the Lease under Section 4.2, Alaxona may terminate the affected Lease on thirty (30) days' notice, or immediately where required by Sanctions.

5. Offers, Orders and Formation of the Lease

5.1 Prices published on the Site are an invitation to submit enquiries, not a binding offer. A binding offer is made only in an Order issued by Alaxona.

5.2 Each Order shall identify at least: the Leased Prefix(es) and their size; the Fees and billing period; the term and its start date; and any agreed options (including sub-allocated PA status under Section 7.6). Minimum order sizes (currently including a minimum of two /24 blocks where /24s are ordered) are as stated in Alaxona's current published pricing or in the Order.

5.3 Unless the Order states a different period, an Order remains open for acceptance for seven (7) calendar days from its date. Alaxona may withdraw an Order at any time before acceptance.

5.4 A Lease is formed when the Customer accepts the Order in text form and Alaxona confirms that acceptance. The Lease takes commercial effect on the Commencement Date.

5.5 Alaxona may decline an accepted Order and rescind the Lease, against a full refund of any payment received for it, where: (a) payment fails or is reversed; (b) verification under Section 4 is not completed to Alaxona's reasonable satisfaction; (c) Alaxona has reasonable grounds to suspect fraud, Sanctions exposure or intended use in breach of the AUP; or (d) the Leased Prefix has become unavailable due to circumstances outside Alaxona's control. Alaxona shall exercise this right within five (5) Business Days of the Customer's acceptance.

6. Delivery and Activation

6.1 Within forty-eight (48) hours of the Commencement Date, Alaxona shall: (a) record the MNT-BY Record in accordance with Section 7.3; (b) create an RPKI Route Origin Authorisation (ROA) for the AS number(s) stated by the Customer; (c) delegate reverse DNS for the Leased Prefix to the name servers designated by the Customer (where requested); and (d) submit the agreed geolocation (geofeed) data (where requested).

6.2 Delivery occurs when the actions in Section 6.1(a) and (b) have been completed, so that the Customer is able to announce the Leased Prefix.

6.3 If Delivery has not occurred within forty-eight (48) hours of the Commencement Date for reasons attributable to Alaxona, the Customer may cancel the affected Lease in text form before Delivery occurs, and Alaxona shall refund all amounts paid for the affected Lease in full.

6.4 Alaxona warrants that on the date of Delivery the Leased Prefix (a) is not subject to entries on the significant, generally used DNS block lists identified in Alaxona's pre-delivery reputation report; (b) is not the subject of a conflicting announcement authorised by Alaxona; and (c) is held and leased in compliance with applicable RIPE NCC policies. The pre-delivery reputation report is provided to the Customer with, or before, the Order.

6.5 Acceptance window. Any claim that the Leased Prefix does not conform to the Lease at Delivery (including under Section 6.4) must be notified to Alaxona in text form within seven (7) calendar days of Delivery. Remedies for timely claims are set out in Section 11.3. After this period, the Leased Prefix is deemed accepted, and claims relating to its condition at Delivery are excluded to the extent permitted by law. This does not affect the Customer's rights under Sections 11.4 (mid-term listings), 13 (Alaxona obligations) or 24 (force majeure).

6.6 Substitution. Alaxona may replace the Leased Prefix with another prefix of at least equivalent size and equivalent characteristics (registry status, reputation) by giving at least thirty (30) days' notice, where reasonably required for the management of its address pool, for compliance with RIPE NCC requirements, or to remedy reputation problems. Alaxona shall provide reasonable technical assistance with renumbering and shall cover its own costs of the substitution. If the substitution is objectively unreasonable for the Customer, the Customer may terminate the affected Lease with effect from the substitution date; Section 11.5 applies.

7. Grant of Rights; Registry Records

7.1 Subject to timely payment and compliance with these Terms, Alaxona grants the Customer a non-exclusive, non-transferable, limited right to use and announce the Leased Prefix during the Lease term, solely for the Customer's own business operations and (where Section 7.6 applies) those of its permitted end users.

7.2 The Lease does not transfer any registration, allocation, title or other proprietary or transferable right in the IP Resources. All such rights remain with Alaxona or the respective holder. The Customer shall not apply to any RIR for transfer or registration of the Leased Prefix.

7.3 Alaxona shall record the MNT-BY Record for the Leased Prefix, naming the maintainer designated by the Customer, and shall keep it in place for the duration of the Lease, subject to Sections 7.5, 16 and 17.

7.4 The MNT-BY Record is provided solely to enable the Customer to manage operational attributes of the Leased Prefix (such as route objects, reverse DNS and contact attributes). The Customer shall not use it to: (a) alter the status, hierarchy of maintainers, or any attribute affecting the registration or holdership of the Leased Prefix; (b) create records that are false or misleading (including WHOIS and abuse contacts); or (c) create route objects or ROAs for AS numbers not agreed under the Lease. The Customer shall keep the contact and abuse-c data associated with the Leased Prefix accurate and current at all times.

7.5 Upon expiry or termination of the Lease, or during a suspension under Section 16, Alaxona may remove or modify the MNT-BY Record, revoke ROAs, and delete objects created by or for the Customer, without further notice. The Customer irrevocably authorises Alaxona to take these steps.

7.6 Sub-leasing; sub-allocated PA. The Customer shall not sub-lease, sub-license, resell or otherwise make the Leased Prefix available to third parties, except that where the Order grants the Leased Prefix sub-allocated PA status, the Customer may make onward assignments to its own customers in accordance with RIPE NCC policies. In that case the Customer: (a) remains fully liable for all use of the Leased Prefix as for its own use; (b) shall impose obligations on its end users no less protective than the AUP; and (c) shall maintain accurate assignment records and provide them to Alaxona on reasonable request.

8. Term, Renewal and Termination

8.1 The Lease runs for the term stated in the Order. Unless the Order states otherwise, the minimum term is three (3) months.

8.2 Unless the Order states otherwise, the Lease renews automatically for successive periods equal to the initial term, unless notice of non-renewal is given in text form: by the Customer, at least thirty (30) days, or by Alaxona, at least sixty (60) days, before the end of the then-current term.

8.3 During a running term neither party may terminate the Lease for convenience. Statutory termination rights for cause, and the termination and rescission rights expressly granted in these Terms (Sections 4.6, 5.5, 6.3, 6.6, 8.4, 8.5, 11.4, 13.5, 23.5, 24.2, 25.2), remain unaffected.

8.4 Either party may terminate the Lease with immediate effect by notice in text form if the other party commits a material breach of the Lease and, where the breach is capable of cure, fails to cure it within fourteen (14) days of notice. The following are material breaches by the Customer not requiring a cure period: breach of the AUP falling within Section 16.1(a); breach of Section 23; payment default persisting more than fourteen (14) days after the due date; unauthorised sub-leasing in breach of Section 7.6; and unaddressed significant abuse, meaning multiple abuse complaints concerning the Leased Prefix (including reports by recognised monitoring services such as Spamhaus) that remain unremediated beyond the periods in Section 15.2.

8.5 Either party may terminate the Lease with immediate effect if IANA or RIPE NCC requires the Lease or the underlying registration to be terminated or materially changed such that performance becomes impossible. Section 24.3 applies to prepaid amounts.

8.6 Upon expiry or termination of the Lease: (a) the Customer shall cease announcing the Leased Prefix and procure its de-announcement (including by its end users) within twenty-four (24) hours of the effective date; (b) Alaxona may exercise its rights under Section 7.5; (c) all sub-leases and onward assignments under Section 7.6 end automatically; and (d) each party shall return or delete the other party's Confidential Information in accordance with Section 21.

8.7 Expiry or termination does not affect rights and obligations accrued before the effective date, including accrued Fees.

8.8 Sections 7.5, 8.6–8.8, 9, 11, 15.5, 17, 18, 19, 20, 21, 26.3, 27 and 28 survive expiry or termination.

9. Fees, Invoicing and Payment

9.1 Fees are as stated in the Order, denominated in euro (EUR) unless the Order states otherwise, and exclusive of VAT and similar taxes.

9.2 Fees are payable in advance for each billing period. Unless the Order states otherwise, the first payment is due upon conclusion of the Lease and subsequent payments at the start of each billing period. Payment methods are as stated in the invoice. A payment is made in time only if the amount is at Alaxona's free disposal by the due date; timely dispatch of the payment is not sufficient.

9.3 If any amount is not received when due: (a) Alaxona may send a reminder; (b) if the default persists for seven (7) days, Alaxona may suspend the Lease under Section 16; (c) if the default persists for fourteen (14) days, Alaxona may terminate the Lease under Section 8.4; and (d) the overdue amount bears interest at 0.05% per day (or the maximum permitted by law, if lower) from the due date until payment, and the Customer shall reimburse Alaxona's reasonable costs of collection.

9.4 The Customer shall pay all amounts without set-off, counterclaim, deduction or withholding, except for set-off of claims that are undisputed or finally adjudicated. The Customer may reduce or retain Fees on account of an alleged defect of the Leased Prefix only where the underlying right is undisputed or has been finally adjudicated; amounts paid without legal cause remain recoverable under the rules on unjust enrichment.

9.5 The Customer shall raise any billing dispute with Alaxona before initiating a chargeback or payment reversal. An unjustified chargeback is a material breach; Alaxona may suspend the Lease until the chargeback is withdrawn, and may charge an administration fee of EUR 50 per chargeback plus the costs imposed on Alaxona by payment providers.

9.6 All taxes, duties and charges arising from the Lease in the Customer's jurisdiction are the Customer's responsibility. If the Customer is required by law to withhold or deduct any amount from a payment, the Customer shall gross up the payment so that Alaxona receives the full amount invoiced.

10. Price Changes

10.1 Fees for a Leased Prefix are fixed for the running term.

10.2 Alaxona may change the Fees with effect from the next renewal by notice in text form at least sixty (60) days before the end of the current term. An increase may not exceed five percent (5%) per renewal.

10.3 If the Customer does not accept an announced increase, the Customer may give notice of non-renewal under Section 8.2; the shorter notice period is deemed observed if such notice is given within fourteen (14) days of the price-change notice.

11. Refunds

11.1 Except as expressly provided in these Terms or the Order, Fees are non-refundable.

11.2 Fees are refundable in full: (a) where the Customer cancels before Delivery under Section 6.3; (b) where Alaxona rescinds under Section 5.5; and (c) for any billing period in respect of which Alaxona failed to deliver the Leased Prefix at all.

11.3 Where the Customer gives timely notice under Section 6.5 that at Delivery: (i) the Leased Prefix was subject to an active conflicting announcement; (ii) the Leased Prefix was listed on the block lists covered by Section 6.4(a); or (iii) the ROA or MNT-BY Record was not created within the 48-hour period, Alaxona shall, at its option and within five (5) Business Days: cure the defect; substitute the prefix under Section 6.6 (without the 30-day notice); or terminate the affected Lease and refund all amounts paid for it.

11.4 If, during the term, the Leased Prefix becomes subject to a listing on the block lists covered by Section 6.4(a) that is not attributable to the traffic or conduct of the Customer or its end users, Alaxona shall use commercially reasonable efforts to obtain delisting, and, if delisting is not achieved within a reasonable period, shall offer a substitution under Section 6.6 (without the 30-day notice). If neither remedy is provided within thirty (30) days of notice, the Customer may terminate the affected Lease and receive a pro-rata refund of prepaid Fees for the unused remainder of the current billing period. No remedy is owed where the listing results from the Customer's or its end users' traffic or conduct.

11.5 Where the Customer terminates due to a substitution under Section 6.6 or a transfer under Section 13.5, or a Lease ends under Section 8.5 or 24.2, Alaxona shall refund the pro-rata part of prepaid Fees attributable to the period after the effective date.

11.6 Refunds are made using the original payment method where technically possible, within fourteen (14) days of the refund becoming due, net of unavoidable third-party payment costs.

12. Customer Obligations

12.1 The Customer shall use the Leased Prefix lawfully, in accordance with these Terms, the AUP, applicable IANA and RIPE NCC policies, and the rules of the networks it connects to.

12.2 The Customer shall announce the Leased Prefix only under the AS number(s) agreed in the Lease and shall maintain the validation objects (route objects, ROAs) required for its announcements throughout the Lease.

12.3 The Customer shall maintain a functioning abuse contact and comply with the abuse-handling obligations in Section 15.

12.4 Where the Customer sends email from the Leased Prefix, it shall maintain proper mail hygiene as set out in Schedule 1, clause S3.

12.5 The Customer shall keep its contact, billing and technical information accurate and current.

12.6 The Customer shall protect its own systems connected with the use of the Leased Prefix against unauthorised access and malware, and shall notify Alaxona without undue delay of any compromise reasonably likely to affect the Leased Prefix or its reputation.

12.7 The Customer shall comply with the de-announcement obligation in Section 8.6(a).

13. Alaxona Obligations

13.1 Alaxona shall, for the duration of the Lease: (a) maintain the allocation or assignment underlying the Leased Prefix and its own compliance with applicable RIPE NCC policies; (b) not transfer, assign or encumber the Leased Prefix in a way that defeats the Customer's rights under the Lease; and (c) maintain the registry records required for the Customer's agreed use.

13.2 Non-interference. Except as permitted under Sections 6.6, 7.5, 16 and 17, Alaxona shall not, during the Lease: (a) remove or modify the MNT-BY Record or ROAs supporting the Customer's agreed announcements; (b) alter registry records in a way that disrupts the routability of the Leased Prefix; or (c) request the Customer's upstream providers to withdraw the Customer's authorised announcements.

13.3 Alaxona shall operate an abuse desk for the Leased Prefix and monitor its reputation as described in Section 15.

13.4 If the Leased Prefix is unusable due to Alaxona's breach of this Section 13, the Customer is entitled to a service credit equal to the Daily Rate for each full day of unusability, applied to the next invoice or, at the end of the Lease, refunded; the total credit per billing period shall not exceed the Fees for that period. This Section 13.4 does not limit Section 20.

13.5 Transfer of holdership. If Alaxona transfers the holdership of, or the right to lease, the Leased Prefix to a third party during the Lease term, the acquirer enters into Alaxona's rights and obligations under the Lease in Alaxona's place, unless Alaxona and the acquirer agree that Alaxona remains the lessor; the Customer's consent to such transfer of the Lease is deemed given in advance. Alaxona shall notify the Customer of the transfer and the identity of the acquirer in text form within fourteen (14) days. If the continuation of the Lease with the acquirer is objectively unreasonable for the Customer for an important reason relating to the acquirer (including Sanctions exposure), the Customer may terminate the Lease on fourteen (14) days' notice, exercisable within fourteen (14) days of the notification; Section 11.5 applies.

14. Acceptable Use

14.1 The AUP in Schedule 1 applies to all use of the Leased Prefix by the Customer and its end users. A breach of the AUP is a breach of the Lease.

15. Abuse Handling and Reputation

15.1 Abuse reports concerning the Leased Prefix may be received by Alaxona directly or via the registry abuse contacts. Alaxona will forward relevant reports to the Customer's abuse contact.

15.2 The Customer shall acknowledge forwarded abuse reports within twenty-four (24) hours and shall remediate confirmed abuse within forty-eight (48) hours of the report, unless a shorter period is required by law or by Section 16.1(a).

15.3 Block-list entries and reputation issues caused by the traffic or conduct of the Customer or its end users are the Customer's responsibility to remediate (including delisting requests); Section 11.4 governs entries not attributable to the Customer.

15.4 Alaxona may charge a reasonable abuse-handling fee, as published or notified in advance, where repeated or grossly negligent AUP violations by the Customer require Alaxona's intervention.

15.5 The Customer shall retain, to the extent permitted by its applicable law, logs sufficient to attribute traffic from the Leased Prefix, and shall provide relevant extracts to Alaxona on reasoned request in connection with abuse investigations. The Customer authorises Alaxona to share information about abuse incidents with RIPE NCC, block-list operators, upstream providers and competent authorities to the extent necessary to investigate and remediate them.

16. Suspension

16.1 Alaxona may suspend the Lease (in whole or in part, including by revoking ROAs and removing the MNT-BY Record for the duration of the suspension):

• (a) immediately and without prior notice, where the Leased Prefix is used for activities under Schedule 1 clauses S2.2–S2.6 (including ongoing attacks, botnet command-and-control, phishing, CSAM), where Sanctions so require, where a competent authority so orders, or where payment default persists beyond the period in Section 9.3(b);
• (b) in all other cases of breach, where the Customer fails to cure within forty-eight (48) hours of notice.

16.2 Emergency action. Independently of breach, Alaxona may take immediate technical measures (including withdrawal of ROAs) where this is objectively necessary to protect the Leased Prefix, Alaxona's other address space or third parties from an ongoing attack, hijack or comparable incident. Alaxona shall notify the Customer without undue delay, and shall lift the measures as soon as the necessity ends. Emergency action under this Section is not a breach of Section 13.2.

16.3 Fees continue to accrue during a suspension caused by the Customer. Suspension does not limit Alaxona's other rights and remedies.

16.4 Alaxona shall lift a suspension without undue delay once its cause has been removed and any reinstatement fee (as published or notified in advance) and outstanding Fees have been paid.

16.5 The Customer may appeal a suspension in text form within five (5) Business Days, describing the measures taken. Alaxona will review the appeal in good faith; measures may remain in place during the review.

17. Consequences of Breach; Liquidated Damages

17.1 Any announcement of the Leased Prefix after the end of the Lease, or during a suspension, or under an AS number not agreed in the Lease, constitutes unauthorised use (hijacking). Alaxona may take all technical and legal measures to stop it, including notifying RIPE NCC, upstream providers and block-list operators.

17.2 For each day of announcement after the deadline in Section 8.6(a), the Customer shall pay liquidated damages equal to two (2) times the Daily Rate, without prejudice to Alaxona's right to claim proven damages exceeding this amount and to the measures in Section 17.1. The parties acknowledge this amount to be a genuine and reasonable pre-estimate of the loss caused by post-termination announcements.

17.3 If Alaxona terminates the Lease under Section 8.4 for the Customer's payment default or other material breach, the remaining Fees for the then-current committed term become immediately due, less expenses saved by Alaxona and any proceeds of re-leasing the Leased Prefix for the remainder of that term.

17.4 The Customer shall reimburse Alaxona for the reasonable costs and losses caused by its breach, including abuse-handling, delisting, legal and collection costs.

18. Warranties and Disclaimers

18.1 Each party represents and warrants that it is duly organised and in good standing, has the right and authority to enter into the Lease, and will comply with applicable law in performing it.

18.2 Alaxona further warrants that: (a) it has the legal right to lease the Leased Prefix for the full term; (b) no third party holds rights in the Leased Prefix that conflict with the Customer's rights under the Lease; and (c) Section 6.4 is true at Delivery.

18.3 Except as expressly stated in these Terms, the IP Resources and all related services are provided "as is", and all implied warranties (including merchantability, fitness for a particular purpose and non-infringement) are disclaimed to the extent permitted by law.

18.4 Alaxona does not provide internet transit, connectivity or BGP sessions, and does not warrant that any third-party network, filtering service, block-list operator or geolocation database will accept, route, list or locate the Leased Prefix in any particular way. No service levels apply to matters outside Alaxona's control.

19. Indemnification

19.1 Alaxona shall defend and hold harmless the Customer against third-party claims alleging that Alaxona lacked the right to lease the Leased Prefix to the Customer, and shall indemnify the Customer against damages finally awarded or agreed in settlement of such claims, including reasonable external legal costs.

19.2 The Customer shall defend and hold harmless Alaxona and the holder of the IP Resources against third-party claims arising out of (a) the Customer's or its end users' use of the Leased Prefix, (b) breach of the AUP or of Section 23, or (c) the Customer's breach of these Terms, and shall indemnify them against damages finally awarded or agreed in settlement, including reasonable external legal costs.

19.3 The indemnified party shall: notify the indemnifying party promptly in text form; allow it sole control of defence and settlement (provided no settlement imposing liability or admission on the indemnified party is made without its consent); and provide reasonable assistance at the indemnifying party's expense. The indemnified party may participate with its own counsel at its own expense.

19.4 Each party shall notify the other in text form within five (5) Business Days of becoming aware of any third-party claim, regulatory enquiry, law-enforcement request or RIR proceeding concerning the Leased Prefix.

20. Limitation of Liability

20.1 Neither party is liable for indirect, incidental, special, consequential, punitive or exemplary damages, or for loss of profits, revenue, goodwill, data or business opportunity, however caused and under any theory of liability, even if advised of the possibility.

20.2 Each party's total aggregate liability arising out of or in connection with a Lease is limited to the Fees paid or payable by the Customer under that Lease during the twelve (12) months preceding the event giving rise to the claim.

20.3 Sections 20.1 and 20.2 do not apply to: (a) liability for intent, gross negligence or fraud; (b) the Customer's payment obligations and liquidated damages under Section 17; (c) either party's indemnification obligations under Section 19; (d) breach of Section 21; or (e) liability for death or personal injury, or any other liability that cannot be limited by law.

20.4 The parties acknowledge that the Fees reflect the allocation of risk in this Section 20 and that it forms an essential basis of the bargain.

21. Confidentiality

21.1 Confidential Information means non-public information disclosed by one party to the other in connection with the Lease that is marked confidential or should reasonably be understood to be confidential, including the terms of the Order. It excludes information that: is or becomes public without breach; was lawfully known to the recipient without duty of confidence; is received from a third party without breach; or is independently developed.

21.2 The recipient shall protect Confidential Information with at least reasonable care, use it only to perform the Lease, and disclose it only to its personnel, affiliates and advisers who need to know it and are bound by confidentiality. Compelled disclosures are permitted with, where lawful, advance notice to the discloser and disclosure limited to what is required.

21.3 On request after the end of the Lease, the recipient shall return or destroy Confidential Information, save for copies required by law or standard backups.

21.4 Neither party shall publicly refer to the other or to the existence of the Lease without the other's consent in text form (email sufficient).

21.5 Breach of this Section may cause irreparable harm; the discloser may seek injunctive relief in addition to other remedies.

22. Data Protection

22.1 Each party shall comply with applicable data protection law with respect to personal data processed in connection with the Lease. Alaxona processes personal data as described in its Privacy Policy published on the Site.

23. Export Control, Sanctions and Anti-Corruption

23.1 Sanctions means economic, financial or trade sanctions, embargoes and restrictive measures imposed, administered or enforced by the United Nations, the United States (including OFAC's SDN and SSI lists), the European Union, or the United Kingdom (including HM Treasury's consolidated list).

23.2 The Customer represents and warrants, on a continuing basis, that neither it nor any of its beneficial owners, directors or officers: (a) is listed on any Sanctions list; (b) is located, incorporated or resident in a country or region subject to comprehensive Sanctions (at the date of these Terms including Cuba, Iran, North Korea, Syria, the Crimea region and Sevastopol, and the non-government-controlled areas of the Donetsk, Luhansk, Kherson and Zaporizhzhia oblasts of Ukraine); (c) is owned or controlled, directly or indirectly, individually or in the aggregate, as to fifty percent (50%) or more, by any person described in (a) or (b); or (d) acts on behalf of, or for the benefit of, any such person.

23.3 The Customer shall not use, and shall not permit the use of, the Leased Prefix by, for, or for the benefit of any person or territory described in Section 23.2, and shall notify Alaxona immediately in text form if any representation in Section 23.2 ceases to be true. The Customer shall provide the information reasonably requested by Alaxona to verify compliance.

23.4 Each party shall comply with applicable anti-corruption and anti-money-laundering laws in connection with the Lease. The Customer shall not use the Leased Prefix in connection with money laundering, terrorist financing, or the offering or acceptance of bribes.

23.5 Alaxona may suspend or terminate the Lease with immediate effect, without liability, where reasonably necessary to comply with Sanctions or where the Customer breaches this Section 23.

24. Force Majeure

24.1 Neither party is liable for failure or delay caused by events beyond its reasonable control, including acts of state, war, terrorism, natural disasters, large-scale failures of internet infrastructure, and acts, omissions or policy changes of IANA or an RIR that materially affect the Leased Prefix (each Force Majeure). The affected party shall notify the other without undue delay and mitigate the effects.

24.2 If a Force Majeure event prevents performance for more than thirty (30) consecutive days, either party may terminate the affected Lease with immediate effect by notice in text form.

24.3 Upon termination under Section 24.2 (or Section 8.5), Alaxona shall refund the pro-rata part of prepaid Fees attributable to the period after the effective date. Obligations accrued before termination remain unaffected.

25. Changes to these Terms

25.1 Alaxona may amend these Terms by publishing the amended version and notifying the Customer in text form at least thirty (30) days before it takes effect. For a Lease with a running committed term, amendments take effect from the next renewal, except amendments required by law or by RIPE NCC policy, which take effect on the notified date.

25.2 If an amendment materially and adversely affects the Customer, the Customer may terminate the affected Lease in text form with effect from the date the amendment takes effect; Section 11.5 applies by analogy to prepaid Fees.

25.3 The version of these Terms referenced in the Order (or, absent a reference, current at conclusion of the Lease) applies until superseded under this Section.

26. Notices, Contact Persons and Records

26.1 Notices under the Lease shall be in text form and sent to the email addresses stated in the Order (or subsequently notified). A notice is deemed received on the Business Day following dispatch, absent evidence of non-delivery.

26.2 Each party shall designate a contact person authorised to receive and send communications concerning the Lease, reachable by email and proficient in English. If a contact person is replaced, a successor shall be named at the same time; until then, notices to the last-named contact person are effective.

26.3 Alaxona keeps electronic records of Orders, invoices and Lease-related notices for at least three (3) years. Each party is responsible for retaining its own copies.

26.4 Documents and declarations exchanged by email or through forms on the Site satisfy any requirement of written or text form under these Terms. The parties accept system logs and electronic records produced in the ordinary course as admissible evidence of use, dates and communications, subject to proof to the contrary.

27. Governing Law and Dispute Resolution

27.1 The Lease and these Terms are governed exclusively by the laws of the Republic of Seychelles, excluding its conflict-of-laws rules. The United Nations Convention on Contracts for the International Sale of Goods (1980) does not apply.

27.2 Before commencing proceedings, the parties shall attempt in good faith to resolve any dispute by negotiation for thirty (30) days from a written dispute notice. This does not prevent either party from seeking urgent injunctive relief.

27.3 The courts of the Republic of Seychelles have exclusive jurisdiction over disputes arising out of or in connection with the Lease, including pre-contractual claims. Alaxona may additionally bring proceedings against the Customer before the courts of the place where the Customer has its seat.

28. Miscellaneous

28.1 Assignment. The Customer may not assign or transfer the Lease or any rights under it without Alaxona's consent in text form. Alaxona may assign the Lease to an affiliate or to a successor in connection with a merger, reorganisation or sale of the relevant business, upon notice to the Customer; a transfer of the holdership of the Leased Prefix is governed by Section 13.5.

28.2 Severability. If any provision is invalid or unenforceable, the remainder stays in force. The invalid provision is replaced by the provision the parties would reasonably have agreed to achieve the same economic purpose.

28.3 Waiver. Failure or delay in exercising a right is not a waiver; a single or partial exercise does not preclude further exercise.

28.4 Entire agreement. The Order and these Terms (with the AUP) constitute the entire agreement concerning the Lease and supersede prior understandings on the same subject. There are no verbal side agreements.

28.5 No partnership. Nothing in these Terms creates a partnership, joint venture, agency or employment relationship.

Schedule 1 — Acceptable Use Policy (AUP)

S1. Purpose and scope. This AUP protects the lawful and secure use of Alaxona's IP Resources and their reputation. It applies to the Customer and to every end user of the Leased Prefix. The Customer is responsible for its end users' compliance.

S2. Prohibited uses. The Leased Prefix must not be used, directly or indirectly:

S2.1 Spam. To send Spam. Spam means any electronic message sent in bulk without the recipient's prior, verifiable, explicit and still-revocable consent, and includes any message that would be considered spam by The Spamhaus Project Ltd (or its successors) under its published criteria, and any message that would breach the U.S. CAN-SPAM Act if that Act applied to the sender.

S2.2 Fraud hosting. To host, operate or support infrastructure or content used to defraud third parties, including phishing or pharming sites, counterfeit or impersonating websites and brands, fraudulent payment pages, malware distribution, and command-and-control infrastructure for botnets.

S2.3 Scams and deception. For scams, advance-fee fraud, investment fraud, deceptive marketing, click fraud, or other fraudulent or deceptive schemes directed at third parties.

S2.4 Network abuse. To conduct denial-of-service attacks; unauthorised scanning, intrusion or penetration of third-party systems; IP or route hijacking or unauthorised route announcements; spoofing; interception; or distribution of malware.

S2.5 Unlawful content. To store or distribute content that is unlawful under the law applicable to the Customer or to the Republic of Seychelles, including child sexual abuse material, content inciting violence, and content infringing third-party intellectual property or privacy rights.

S2.6 Sanctioned use. In breach of Section 23 of the Terms (Sanctions, export control, anti-corruption/AML).

S2.7 Other unlawful use. For any other purpose prohibited by applicable law, or in breach of applicable IANA or RIPE NCC policies (including deliberately false registry data).

S3. Mail hygiene. Where email is sent from the Leased Prefix, the Customer shall maintain valid PTR records; publish and maintain appropriate SPF, DKIM and DMARC records; and not operate open relays, open proxies or open resolvers or other amplification vectors on the Leased Prefix.

S4. Enforcement. Breach of this AUP is a material breach of the Lease. Sections 15 (abuse handling), 16 (suspension) and 17 (consequences of breach) of the Terms apply.

Refund Policy

Version 2.0 — in force from 9 August 2026

Refunds for the leasing of IP Resources are governed by Section 11 (Refunds) of the General Terms and Conditions above, read together with Sections 5.5 (rescission of an Order), 6.3 and 6.4 (non-delivery and pre-delivery warranty), 6.6 (substitution), 8.5 and 24 (termination for RIR action or force majeure), and 9.5 (chargebacks). This Refund Policy does not create any right in addition to those Sections; it summarises them for convenience.

1. When a refund is due

Fees are refundable in the following cases, as set out in Section 11 of the Terms:

• the Customer cancels before Delivery because Alaxona has not delivered the Leased Prefix within 48 hours (Section 6.3) — full refund;
• Alaxona rescinds an accepted Order under Section 5.5 — full refund;
• Alaxona fails to deliver the Leased Prefix for a billing period at all — full refund for that period;
• a defect notified within the 7-day acceptance window under Section 6.5 is confirmed (conflicting announcement, blocklist entry present at Delivery, or MNT-BY/ROA not created in time) — cure, substitution or full refund, at Alaxona's option (Section 11.3);
• a blocklist entry arises during the term that is not attributable to the Customer and is neither delisted nor cured by substitution within a reasonable period — pro-rata refund for the unused remainder of the billing period (Section 11.4);
• the Lease ends due to a substitution the Customer reasonably declines (Section 6.6), a transfer of holdership the Customer reasonably declines (Section 13.5), a RIPE NCC or IANA requirement (Section 8.5), or force majeure lasting more than 30 days (Section 24.2) — pro-rata refund of prepaid Fees for the period after the effective date (Section 11.5).

2. When no refund is due

Except as listed in Section 1 above, Fees are non-refundable once the billing period has begun (Section 11.1). This applies in particular where the Customer terminates for convenience, where the Lease is terminated for the Customer's breach (including abuse, unlawful use, non-payment or false information — Sections 8.4 and 17.3), and to blocklist entries or reputation problems caused by the Customer's own traffic or that of its end users (Section 15.3).

3. How to request a refund

Refund requests shall be submitted in text form to the contact person designated by Alaxona, stating the invoice number, the amount and the reason for the request. Where a refund is due under Section 1 above, Alaxona processes it within fourteen (14) days using the original payment method where technically possible, net of unavoidable third-party payment costs (Section 11.6).

4. Chargebacks

The Customer shall raise any billing dispute with Alaxona before initiating a chargeback or payment reversal. An unjustified chargeback is a material breach of the Terms; see Section 9.5 for the applicable administration fee and Alaxona's right to suspend the Lease until the chargeback is withdrawn.

Privacy Policy

As of: 11 August 2026

1. Introduction and Scope

1.1 This Privacy Policy explains which personal data Alaxona collects, processes and transfers, why, how we keep it secure, how long we keep it, and how you can exercise your rights.

1.2 "Personal data" means any information relating to an identified or identifiable person — for example a name, an email address, an IP address, or the content of a message.

1.3 This Policy applies to the processing of personal data about you as:

• a visitor of the website alaxona.com (the Site);
• a person who submits an enquiry through the Site;
• a contact person, representative or beneficial owner of a former, current or prospective customer or counterparty of Alaxona;
• a technical or abuse contact designated in connection with a lease of IP resources.

1.4 Alaxona is established in the Republic of Seychelles. Where we offer services to, or process the personal data of, individuals located in the European Economic Area or the United Kingdom, additional rights and safeguards apply — see Section 19.

1.5 The Site may contain links to third-party websites. Their operators are independently responsible for their own processing; we encourage you to read their privacy policies.

2. Who Is Responsible, and How to Reach Us

2.1 The company responsible for the personal data described in this Policy is:

2.2 We have designated an individual responsible for ensuring that we handle personal data properly. That person's business contact details are:

2.3 All requests and complaints concerning personal data should be addressed in writing to the Data Protection Contact at the address above. The Data Protection Contact monitors how we handle personal data and is the focal point for requests and complaints.

3. Personal Data We Collect

3.1 Data you provide. When you submit an enquiry or conclude a lease, we collect the data you — or the company you represent — provide, which may include:

• contact information: name, company, email address, phone number, postal address;
• business and technical information: company registration details, tax or VAT number, autonomous system number (ASN), LIR ID, NOC and abuse contact details, and maintainer details for the RIPE Database;
• the content of your enquiry and subsequent correspondence;
• billing information needed for invoicing.

3.2 Verification data. Before or during a lease we may collect, directly or through our payment provider (Section 5): identity documents of authorised representatives; proof of address; company registration and constitutional documents; details of ultimate beneficial owners, including name, date of birth, nationality and residential address; and bank account details used for payment.

3.3 Data collected automatically. When you visit the Site, technical access data is processed: IP address, date and time of access, the URL requested, referrer, browser, device and operating system information, and technical connection and security data. See Sections 6 and 7.

3.4 Data obtained from other sources. We may verify information you provide against public company registers, the public databases of the Regional Internet Registries, and publicly available sanctions lists. See Section 10.

3.5 We do not process special or sensitive categories of personal data — data revealing racial or ethnic origin, biometric or genetic data, political opinions, religious or philosophical beliefs, or data concerning health or sex life — and we ask you not to provide such data to us.

3.6 Where certain data is required to answer an enquiry, to conclude or perform a lease, or to meet a legal obligation, we cannot provide the relevant service without it. We do not ask you to agree to processing that goes beyond what these purposes require.

4. Why We Process Personal Data

4.1 We process personal data for the purposes below, on the grounds set out alongside each of them:

4.2 We keep the personal data we process to the minimum necessary for these purposes, and take reasonable steps to keep it accurate, complete and up to date.

4.3 We process personal data for other purposes only where this is lawful and compatible with the purpose for which the data was collected. If we need to use personal data for an unrelated purpose, we will inform you and explain the grounds for it.

4.4 Where we process personal data because you have agreed to it, you may withdraw that agreement at any time with effect for the future.

5. Verification and Payments — Stripe

5.1 KYC verification and payments may be processed through Stripe. By providing the data, you also agree to Stripe's Privacy Policy (https://stripe.com/privacy).

5.2 Where this applies, identity documents, beneficial-owner details, payment card data and bank account details are collected and processed by Stripe on our behalf and under its own regulatory obligations. For certain purposes — in particular fraud prevention and its own legal compliance — Stripe decides for itself how and why it processes the data it handles.

5.3 Alaxona does not itself store full payment card numbers.

6. Cookies and Analytics

6.1 The Site does not use advertising, profiling or cross-site tracking cookies. No consent banner is displayed because no technologies requiring your agreement are used.

6.2 Analytics — Pirsch. We measure Site usage with Pirsch Analytics (Pirsch Analytics GmbH, Germany), a cookieless, privacy-preserving analytics service hosted in the European Union. Pirsch processes page views, referrer, browser and device type, and approximate region, on an aggregated basis. It does not use cookies, does not build individual visitor profiles, does not track visitors across other websites, and does not store your IP address.

We count page views from our own server rather than by loading any analytics script into your browser. Your browser therefore never contacts the analytics provider, and no analytics code runs on your device.

6.3 Anti-spam — Cloudflare Turnstile. The contact form is protected by Cloudflare Turnstile, which distinguishes human visitors from automated systems. Turnstile may process your IP address, browser and device information, interaction data and a result token, and may store a strictly necessary entry on your device for the duration of the check. According to Cloudflare, Turnstile does not use this data for advertising and does not track users across websites. We use it because we have a legitimate interest in protecting the form from automated abuse.

7. Hosting, Delivery and Service Providers

7.1 We operate the Site and our systems on the infrastructure of the providers listed below. Each is engaged under a written agreement under which the provider acts only on our instructions, keeps the data confidential, assists us with requests from individuals, and deletes or returns the data at the end of the engagement.

7.2 Enquiries submitted through the Site are transmitted over the infrastructure listed above and delivered to our mailbox by Sweego, our transactional email provider.

7.3 Apart from these providers, personal data may be disclosed to: professional advisers such as lawyers, auditors, accountants and insurers; banks and payment institutions; RIPE NCC and other Regional Internet Registries (Section 8); competent authorities and courts where we are legally required to disclose it or where a lawful request is made; and, in the event of a merger, reorganisation or sale of the relevant business, to the acquirer, which will be required to honour this Policy.

7.4 If we engage a new provider or replace an existing one, we will update the list in this Policy before the change takes effect and notify customers with active leases by email.

8. Publication in the RIPE Database

8.1 Performing a lease requires creating and maintaining records in the RIPE Database — the public registry operated by RIPE NCC. Depending on the configuration agreed with the customer, these records — such as inetnum, person, role, abuse-c and maintainer (MNT-BY) objects — may contain personal data of the customer's designated contacts: names, email addresses and phone numbers.

8.2 The RIPE Database is public and searchable. Data published in it is accessible worldwide, is mirrored by other Regional Internet Registries, and may be copied by third parties. We publish this data because it is necessary to perform the lease and to comply with the policies of the registry that administers the resources.

This publication is also governed by the RIPE NCC Privacy Statement (https://www.ripe.net/about-us/legal/ripe-ncc-privacy-statement/), which applies to all personal data held in the RIPE Database. By providing contact data for publication in the RIPE Database — or by having it provided on your behalf — you accept that the RIPE NCC Privacy Statement applies to that data in addition to this Policy. We recommend that you read it before providing such data.

8.3 We inform designated contact persons of this publication by making this Policy available to them, and the customer shall inform the individuals it designates before providing their data to us. Under the RIPE NCC Privacy Statement, the maintainer recorded as "mnt-by:" on a record is responsible for the personal data it enters into the RIPE Database and for obtaining the relevant individual's agreement where this is required. Where we record the customer as MNT-BY, as provided in our Terms, that responsibility rests with the customer.

8.4 RIPE NCC decides for itself how and why it processes RIPE Database data, under its own framework. Requests concerning data in the RIPE Database should be addressed in the first place to the maintainer of the record. Where the maintainer does not respond, RIPE NCC operates a procedure for the removal of personal contact details from the RIPE Database, and complaints about RIPE NCC's own processing may be made to the Dutch data protection authority. We will assist with requests concerning objects under our control, and upon expiry or termination of a lease we remove or replace the lease-related objects we control.

8.5 Where a customer holding sub-allocated PA status registers assignments for its own end users, the related registry data reaches us and RIPE NCC through that customer. The customer is responsible for the lawfulness of that transfer and for informing the individuals concerned. We process such data only for registry administration and abuse handling.

9. Abuse Handling Data

9.1 When abuse involving leased IP resources is reported, we process the data contained in the report — including the reporter's contact details and a description of the incident — together with related log extracts provided by the customer and our own technical observations.

9.2 We use this data to investigate and remediate incidents, to protect the reputation and security of our address space, and to meet our legal obligations. Where necessary for these purposes, incident information may be shared with the customer concerned, RIPE NCC, block-list operators, upstream network operators and competent authorities.

9.3 We do this because we have a legitimate interest in the secure and lawful operation of our resources, and because we are in some cases legally required to.

10. Customer Verification and Sanctions Screening

10.1 Before and during a lease we verify customers and screen the customer, its representatives, directors and beneficial owners against publicly available sanctions lists, including United Nations, European Union, United Kingdom and United States lists, as required by our Terms and by the law that applies to us.

10.2 Screening results are documented and retained as part of our compliance records.

10.3 A decision to decline or terminate a lease is never taken solely by automated means. Any screening match is reviewed by a person before a decision is made. See also Section 15.

11. Transfers of Data Outside Seychelles

11.1 We are established in the Republic of Seychelles, and the infrastructure we use is located outside Seychelles. We transfer personal data outside Seychelles only where the recipient ensures a comparable level of protection for the rights and freedoms of the individuals concerned.

11.2 Before engaging each provider listed in Section 7, we assess whether that condition is met, taking into account the nature of the personal data, the purposes and the period for which it is to be processed, the law in force in the country of destination, and any applicable data protection arrangements. On that basis:

• Hetzner, Sweego and Pirsch are established in the European Union and process the data there, under a data protection regime that provides a comparable level of protection. Sweego's own sub-processors are located in France and the Netherlands;
• Cloudflare and Stripe are engaged under written data protection agreements that include recognised standard safeguards for international data transfers, supported where appropriate by additional technical and organisational measures.

11.3 The location of processing for each provider is stated in the table in Section 7.

11.4 Data published in the RIPE Database (Section 8) is, by the nature of that public registry, accessible worldwide. That publication is inherent in the service and is separate from the transfers described in this Section.

12. How Long We Keep Personal Data

12.1 We keep personal data only for the period necessary for the purposes for which it is processed:

12.2 We set specific periods having regard to the amount, nature and sensitivity of the data, the risk of harm from unauthorised use or disclosure, the purposes of processing, and the legal requirements that apply to us.

12.3 Once the retention period has elapsed, the data is anonymised, archived or erased. Where data must be kept for establishing, exercising or defending legal claims, or to meet a legal obligation, we restrict its use to those purposes instead of deleting it.

13. Security and Data Breaches

13.1 We apply technical, organisational and physical measures appropriate to the risks arising from the processing, including: encryption of data in transit; access controls and authentication; separation of production systems; hosting of stored data in the European Union; internal confidentiality obligations; and periodic review of the measures in place.

13.2 We keep records of our processing activities and logs of processing operations, including records of who has consulted personal data and to whom it has been disclosed, and we make these available to the supervisory authority on request.

13.3 No method of transmission or storage is completely secure, and transmission of information over the internet is at your own risk. You are responsible for keeping your own credentials and systems secure.

13.4 Data breaches. We notify the Information Commission of a personal data breach no later than seventy-two (72) hours after becoming aware of it and, where that is not possible, we give reasons for the delay. The notification states the nature of the breach, the categories and approximate number of individuals and records concerned, a contact point for further information, the likely consequences, and the measures taken or proposed. Where a breach is likely to affect a significant number of individuals and their rights and freedoms, we also inform those individuals promptly, with the same information. We record every breach, its effects and the remedial action taken.

14. We Do Not Sell Personal Data

We do not sell, rent or trade personal data, and we do not disclose it to third parties for their own marketing purposes. We do not use the details submitted through the contact form for newsletters or other marketing communications.

15. Automated Decision-Making and Profiling

We do not take decisions about you based solely on automated processing, and we do not build profiles about you. As stated in Section 10.3, sanctions-screening matches are always reviewed by a person before any decision is made.

16. Your Rights

16.1 You have the following rights in relation to your personal data.

Access. You may obtain confirmation of whether we process your personal data and, if we do:

• the data undergoing processing and any available information about where it came from;
• the purposes of the processing and the grounds on which we rely;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the data has been disclosed, including recipients in other countries or international organisations;
• a list of the recipients that accessed your data in the six (6) months preceding your request;
• the period for which the data will be stored or, where that is not possible, the criteria used to determine that period.

Correction. You may ask us to correct data that is inaccurate, incomplete or not up to date. If we disagree with your request we will explain why, and you may complain to the Information Commission. Where we correct data, we also inform you and everyone who accessed that data in the six (6) months preceding the request.

Deletion. You may ask us to delete your personal data. We delete it where processing it would be unlawful or where we are required to do so, whether or not you ask us.

Blocking and restriction. You may ask us to block access to your data. We restrict processing instead of deleting where the data must be kept as evidence, or where you contest its accuracy and this cannot be verified.

Objection. You may restrict or prevent processing where it has served its purpose and is no longer necessary, where the ground we relied on no longer applies, or where the processing is unlawful.

Portability. You may ask to receive your personal data in a structured, machine-readable and interoperable format, or to have it transferred to another organisation.

Withdrawing your agreement. Where processing is based on your agreement, you may withdraw it at any time with effect for the future.

Compensation. You have the right to compensation for material or non-material damage suffered as a result of unlawful processing of your personal data.

16.2 How to exercise your rights. Send your request in writing to the Data Protection Contact at the postal address in Section 2.2. Rights may be exercised personally or through a legal or voluntary representative.

16.3 Time and cost. We respond within thirty (30) days. Responding to your request is free of charge. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or decline to act on it, and we will tell you why.

16.4 Identity checks. To prevent unauthorised disclosure, we may ask for additional information to confirm your identity and may delay dealing with a request until your identity is confirmed.

16.5 Limits. We may restrict the information we provide, wholly or partly, where this is a necessary and proportionate measure to avoid obstructing an official or legal inquiry, investigation or procedure; to avoid prejudicing the prevention, detection, investigation or prosecution of criminal offences; to protect public security or national security; or to protect the rights and freedoms of others. If we do, we will tell you in writing that the information has been restricted, give our reasons, and explain that you may ask the Information Commission to verify that the restriction is lawful, complain to it, or appeal to a court.

16.6 Complaints. You may lodge a complaint with the Information Commission, the authority responsible for supervising how personal data is handled in Seychelles:

16.7 Data published in the RIPE Database (Section 8) is also subject to RIPE NCC's own procedures and the RIPE NCC Privacy Statement. We will assist with requests concerning objects under our control.

17. Business Use Only; Minors

The Site and our services are directed exclusively at businesses and their representatives, not at consumers or at persons under the age of 18. We do not knowingly process the personal data of anyone under 18. If you believe a minor has provided us with personal data, write to the Data Protection Contact (Section 2.2) and we will delete it without undue delay.

18. Changes to this Policy

We review this Policy at least annually and update it whenever our processing activities, our providers or the requirements that apply to us change, so that it remains a detailed and accurate description of how we handle and transfer personal data. The version published on the Site applies; its date is stated below the title. If a change is material, we will announce it in a manner reasonably likely to reach you, and customers with active leases will be notified by email before the change takes effect.

19. Additional Rights for Individuals in the European Economic Area and the United Kingdom

19.1 We offer our services to customers in the European Economic Area and the United Kingdom. Individuals located there have the additional rights set out below, and benefit from the additional safeguards described in this Policy. Where the protection available to you under this Section differs from the protection described elsewhere in this Policy, we apply the stronger one.

19.2 Additional rights. In addition to the rights in Section 16, you may ask us to restrict how we use your personal data, and you may object at any time, on grounds relating to your particular situation, to processing that we carry out on the basis of our legitimate interests. Following such an objection we will stop the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. We respond to requests from individuals located in these territories within one month.

19.3 Transfers. Because we are established outside the European Economic Area, personal data you provide to us is transferred to a country that has not been formally recognised as offering an equivalent level of protection. Such transfers rely on one of the following: a formal recognition of the destination country's data protection standards; a valid certification of the recipient under a recognised data protection framework; standard contractual safeguards approved for international transfers, supported where appropriate by additional technical and organisational measures; or, in exceptional cases, a recognised exception. The arrangements for each provider are described in Section 11.2.

19.4 Complaints. In addition to the Information Commission (Section 16.6), you may lodge a complaint with the data protection authority of your habitual residence, your place of work, or the place where you consider the infringement took place.