Legal Framework

Section 1 — Purpose

1.1 General Purpose

The DaDa Design Legal Framework has been prepared to bring under a single legal system the creation, management, marketing, sale and digital delivery of digital collectible assets offered under the DaDa Design® brand developed by TRAFO e.U., together with the protection of intellectual property rights, regulation of user relationships, protection of personal data and corporate governance processes.

This Framework is not merely a collection of website agreements. It is also the principal document establishing DaDa Design’s corporate legal infrastructure, compliance system, governance principles and rules governing digital asset management.

All agreements, policies, notices, procedures and other related documents forming part of this Framework constitute integral parts of this Master Foundation and, unless expressly stated otherwise, shall be interpreted and applied together.

1.2 Legal Purpose

This Framework serves the following principal purposes:

a) To define the rights and obligations of the parties clearly, comprehensibly and predictably.

b) To regulate the legal processes relating to the sale of Digital Collectible Assets.

c) To standardise digital delivery processes.

d) To protect intellectual property rights.

e) To distinguish clearly between ownership rights and copyright.

f) To ensure the protection of users’ personal data.

g) To establish a legal infrastructure compliant with the laws of the Republic of Austria and the legislation of the European Union.

h) To establish predictable rules designed to help prevent legal disputes.

i) To support DaDa Design’s sustainable corporate governance structure.

1.3 Commercial Purpose

The commercial purpose of the Framework is to ensure that the digital collectible ecosystem developed by DaDa Design operates in a reliable, transparent and sustainable manner.

In this context, the objectives are:

• increasing user confidence;

• supporting digital collecting culture;

• developing the digital ownership model;

• preserving collection integrity;

• safeguarding the limited-edition system; and

• standardising electronic commerce processes.

The aim is to develop this structure sustainably over the long term.

1.4 Corporate Purpose

This Framework also constitutes the corporate legal management system of TRAFO e.U.

The corporate objectives are:

• reducing legal risks;

• standardising business processes;

• preserving document integrity;

• ensuring regulatory compliance;

• centrally managing internal procedures;

• ensuring version control; and

• establishing a standard for legal documentation.

1.5 User-Oriented Objectives

This Framework is intended to enable users to understand clearly and comprehensibly:

• the rights available to them;

• the obligations they assume;

• the procedures applicable in particular circumstances; and

• the legal status of purchased Digital Collectible Assets.

Accordingly, the legal language used throughout the Framework is drafted, to the greatest extent reasonably possible, in a clear, comprehensible and consistent manner designed to minimise differences in interpretation.

1.6 Protection of the Digital Collectible Model

The digital collectible model adopted by DaDa Design differs from a conventional digital-product sales model.

The Framework is based on a legal model under which ownership of a Digital Collectible Asset may be transferred while copyright and other intellectual property rights in the work remain with the author or other relevant rights holder.

This approach reflects intellectual-property principles internationally recognised in connection with the sale of works of art.

1.7 Principle of Continuity

This Framework is a living document.

It may be updated in response to technological developments, legislative changes, the development of the business model and innovations within the digital collectible ecosystem.

Any updates shall be prepared with due regard to:

• legal certainty;

• transparency; and

• protection of user rights.

Updates shall apply from their effective date and, unless expressly stated otherwise or required by mandatory law, shall not affect prior legal transactions retroactively.

1.8 Fundamental Principles of the Framework

This Framework is based on the following principles:

• Rule of law

• Transparency

• Integrity

• Good faith

• Legal certainty and predictability

• Proportionality

• Data security

• Protection of intellectual property

• Protection of digital ownership

• Corporate sustainability

• User trust

• Technological neutrality

• Continuous improvement

Section 2 — Scope

2.1 General Scope

This Legal Framework is the principal legal document covering all digital products, services, user relationships, commercial activities, digital delivery processes and corporate governance practices offered under the DaDa Design brand operated by TRAFO e.U.

In addition to agreements published on the website, the Framework covers internal legal procedures, compliance rules, corporate governance principles and operational legal standards.

All documents forming part of this Framework shall be regarded as a single integrated body and contain provisions that complement one another.

2.2 Personal Scope

This Framework applies to the following persons and organisations:

a) Visitors

Persons who visit the DaDa Design website or digital platforms without creating an account.

b) Users

Natural or legal persons who use the Platform, view content or make use of any service.

c) Members

Persons who create a user account on the Platform.

d) Buyers

Natural or legal persons who purchase Digital Collectible Assets offered by DaDa Design.

e) Rights Holders

Persons holding rights in Digital Collectible Assets purchased by them, to the extent defined by the applicable agreement and mandatory law.

f) Business Partners

Natural or legal persons engaged in commercial, technical or operational cooperation with DaDa Design.

g) Service Providers

Payment institutions, hosting providers, infrastructure service providers, certification service providers and other third-party service providers.

2.3 Subject-Matter Scope

This Framework covers the following activities:

Digital Collectible Assets:

• design;

• creation;

• publication;

• offering for sale;

• marketing;

• certification;

• digital delivery;

• verification;

• archiving;

• updating; and

• collection management.

User Transactions:

• creation of memberships;

• login procedures;

• account management;

• placement of orders;

• payment transactions;

• user-support processes; and

• complaint management.

Commercial Processes:

• electronic commerce;

• distance selling;

• digital delivery;

• electronic invoicing;

• payment management;

• refund processes; and

• technical support.

Legal Processes:

• protection of copyright;

• protection of trademark rights;

• protection of design rights;

• creation of ownership records;

• maintenance of electronic records;

• preservation of legal evidence; and

• dispute management.

2.4 Platform Scope

This Framework applies to the following systems operated by DaDa Design:

• the website;

• mobile applications;

• customer portal;

• payment systems;

• digital delivery systems;

• certificate-verification systems; and

• all digital platforms developed in the future.

Technological development of the Platform or the addition of new services shall not prevent the continued application of this Framework.

2.5 Geographical Scope

DaDa Design is operated from the Republic of Austria. Owing to the nature of digital services, however, its products and services may be accessible to users internationally.

Accordingly, the Framework is designed to cover international electronic commerce, cross-border digital delivery and legal relationships established with users located in different countries.

Specific provisions in the relevant agreements concerning governing law and competent jurisdiction remain unaffected.

2.6 Scope of the Digital Collectible Model

This Framework does not regulate only conventional digital-product sales.

It also covers:

• Unique Digital Collectible Assets;

• Limited-Edition Digital Collectible Assets;

• Collection Series;

• Digital Artworks;

• Digital Design Collections;

• Digital Certificates; and

• new collection formats developed in the future.

The Framework has been designed with sufficient flexibility to accommodate technological developments.

2.7 Intellectual Property Scope

This Framework establishes fundamental principles concerning:

• authorship;

• copyright;

• design rights;

• trademark rights;

• commercial-use rights;

• licensing rules; and

• protection of ownership rights.

All specific policies prepared in this context form an integral part of this Framework.

2.8 Data-Protection Scope

The Framework covers the processing, storage, protection, transfer, deletion and anonymisation of personal data, as well as data-security processes.

Detailed provisions on data protection are set out separately in the Privacy Policy and GDPR Compliance documentation.

2.9 Corporate Scope

This Framework is not merely a collection of agreements intended for users.

It is also the principal reference document for legal management, document management, risk management, compliance processes, corporate governance and operational legal practices carried out by TRAFO e.U.

Employees and authorised persons of the Business shall act in accordance with the principles of this Framework within their respective areas of responsibility.

2.10 Future Services

Any new products, services, technologies or digital collectible models that DaDa Design may offer in the future shall fall within the scope of this Framework insofar as they are consistent with its fundamental principles.

Additional policies, procedures or agreements may be prepared where necessary for new services.

2.11 Interpretation of Scope

The scope provisions of this Section shall be interpreted broadly, subject always to mandatory law.

Where uncertainty exists as to whether a service or transaction falls within the Framework, interpretation shall take account of:

• the purpose of the Framework;

• the digital collectible model;

• user safety and protection;

• legal certainty and predictability;

• the principle of good faith; and

• Austrian and European Union law.

Section 3 — Legal Basis

3.1 General Principle

The DaDa Design Legal Framework has been prepared on the basis of the legal system of the Republic of Austria and the legal order of the European Union.

In preparing the Framework, mandatory legal rules, consumer-protection provisions, electronic-commerce regulations, data-protection principles and intellectual-property legislation have been considered together.

Nothing in this Framework is intended to exclude or override mandatory provisions of applicable law.

Consumer rights, data-protection rights and fundamental rights that cannot lawfully be waived or modified remain fully reserved.

3.2 Governing Legal Framework

As DaDa Design is operated from the Republic of Austria, Austrian law constitutes the principal legal system underlying this Framework.

However, owing to the international nature of the services, European Union law and relevant principles of international electronic commerce have also been taken into account.

The Framework has therefore been prepared within the context of:

• Austrian law;

• European Union law; and

• relevant principles of international electronic commerce.

3.3 Austrian Legislation

The following principal Austrian legislation has been taken into account:

a) Allgemeines Bürgerliches Gesetzbuch (ABGB) – Austrian General Civil Code

Applicable to fundamental obligations between the parties, contracts, legal transactions, ownership relationships and general private-law matters.

b) Konsumentenschutzgesetz (KSchG) – Austrian Consumer Protection Act

Establishes core consumer-protection principles. The Framework is based, in particular, on fairness, transparency, prevention of unfair contractual terms and proper consumer information.

c) Fern- und Auswärtsgeschäfte-Gesetz (FAGG) – Austrian Distance and Off-Premises Contracts Act

Relevant to distance contracts, electronic orders, digital delivery and statutory withdrawal rights.

d) E-Commerce-Gesetz (ECG) – Austrian E-Commerce Act

Relevant to electronic-commerce activities, contracts concluded online, electronic communications and obligations of service providers.

e) Verbrauchergewährleistungsgesetz (VGG) – Austrian Consumer Warranty Act

Relevant to digital content, digital services and consumers’ statutory remedies for lack of conformity.

f) Urheberrechtsgesetz (UrhG) – Austrian Copyright Act

A principal legal reference for provisions concerning copyright, authorship and intellectual-property rights.

g) Datenschutzgesetz (DSG) – Austrian Data Protection Act

Relevant national data-protection provisions have been taken into account.

3.4 European Union Law

The following European Union instruments and legal frameworks have been taken into account:

General Data Protection Regulation (GDPR)

Processing, storage, transfer and deletion of personal data and data-security processes are governed by GDPR principles.

Directive (EU) 2019/770 on certain aspects concerning contracts for the supply of digital content and digital services

A principal reference for the supply of digital content, digital delivery, lack of conformity and consumer rights.

DaDa Design’s Digital Collectible Assets may constitute digital content for the purposes of applicable consumer law, depending on the relevant transaction.

Consumer Rights Directive

Relevant to distance selling, pre-contractual information, transparency and consumer-information obligations.

Omnibus Directive

Relevant to pricing, commercial practices and accuracy of information presented to consumers.

E-Commerce Directive

Relevant to electronic-commerce services, information-society services and commercial activities offered online.

3.5 Electronic-Commerce Principles

The Framework adopts the following core electronic-commerce principles:

• Transparency

• Reliability

• Creation and preservation of electronic evidence

• Recording of digital delivery

• Order security

• Electronic-payment security

• Prior information to the user

• Explicit consent where legally required

• Explicit confirmation

• Integrity of electronic records

3.6 Intellectual-Property Principles

The Framework adopts the following fundamental principle recognised in intellectual-property law:

The sale of a Digital Collectible Asset does not, by itself, constitute an assignment of copyright in the underlying work.

Ownership or contractual rights relating to the acquired digital asset and intellectual-property rights in the work are legally distinct.

This distinction is a fundamental legal principle of the Framework.

3.7 Data-Protection Principles

All personal-data processing activities under the Framework shall be conducted in accordance with:

• lawfulness;

• fairness;

• transparency;

• data minimisation;

• purpose limitation;

• accuracy;

• storage limitation;

• confidentiality;

• security; and

• accountability.

3.8 Principle of Technological Neutrality

This Framework is not tied to any particular technology.

Its fundamental legal principles shall continue to apply where technology develops, new digital-delivery methods emerge, new digital collectible formats are created or electronic-commerce practices change.

This principle is intended to support the Framework’s long-term relevance.

3.9 Priority of Mandatory Law

If any provision of this Framework conflicts with Austrian law, European Union law or any other mandatory rule that must legally be applied, the relevant mandatory rule shall prevail.

Such conflict shall affect only the provision concerned, and the remaining provisions shall continue to apply to the extent legally permissible.

3.10 Adaptation to Legal Developments

DaDa Design recognises that law and technology continually evolve.

The Framework shall therefore be reviewed periodically in light of new legislation, judicial decisions, European Union measures and sector developments.

New versions may be published where considered necessary.

3.11 Conclusion

This Framework is not intended solely to achieve formal compliance with applicable law.

It also forms the foundation of a corporate management system based on legal certainty, corporate sustainability, protection of intellectual property and user trust.

Accordingly, its provisions shall be assessed not only as individual contractual provisions but as parts of an integrated legal framework.

Section 4 — Legal Principles

4.1 General Principle

All agreements, policies, procedures and practices forming part of this Framework have been prepared in accordance with the legal principles set out below and shall be interpreted and applied in light of those principles.

These principles are not merely rules of legal interpretation; they also reflect DaDa Design’s approach to corporate governance and commercial ethics.

4.2 Rule of Law

DaDa Design undertakes to conduct its commercial activities in accordance with the laws of the Republic of Austria, European Union law and any directly applicable mandatory rules of international law.

No provision of this Framework may be interpreted so as to exclude or restrict mandatory legal provisions.

4.3 Legal Certainty

DaDa Design seeks to establish clear, comprehensible and consistent rules enabling users to understand their rights and obligations in advance.

Accordingly, agreements shall be structured so as to be:

• clear;

• comprehensible;

• internally consistent; and

• systematic.

Ambiguous wording should be avoided wherever reasonably possible.

4.4 Transparency

Information provided to users shall be accurate, current, complete and verifiable to the extent required by applicable law.

Pricing, product characteristics, delivery methods, certificate information and user rights shall be stated clearly.

No user shall be induced to enter into a transaction on the basis of misleading or materially incomplete information.

4.5 Integrity and Good Faith

The parties shall act in accordance with the principles of good faith and fair dealing in their legal relationships.

No right may be interpreted or exercised abusively.

No party may rely on this Framework in a manner intended unlawfully to prejudice the other party.

4.6 Digital Ownership Principle

Certain rights relating to Digital Collectible Assets offered by DaDa Design may be transferred to the user as specified in the applicable sales terms.

Unless expressly agreed otherwise in writing, such acquisition does not include copyright, design rights, trademark rights or other intellectual-property rights in the underlying work.

This distinction is a fundamental principle of the Framework.

4.7 Separation of Ownership and Intellectual Property

The transfer of rights in a Digital Collectible Asset and the transfer or licensing of intellectual-property rights in the underlying work are separate legal transactions.

Acquisition of the Digital Collectible Asset does not by itself include rights of reproduction, distribution, adaptation, commercial exploitation or licensing.

Unless expressly agreed otherwise in writing, such intellectual-property rights remain with TRAFO e.U. or the relevant rights holder.

4.8 Limited-Edition Integrity

Collections announced as limited editions shall be limited to the quantity publicly stated for the relevant edition.

DaDa Design regards preservation of collection integrity as a fundamental ethical and commercial principle.

The announced edition size shall not subsequently be increased, subject to correction of manifest technical errors and mandatory law.

This principle is intended to protect user and collector confidence.

4.9 Authenticity

Each Digital Collectible Asset is treated as an original design created or lawfully offered by DaDa Design.

Each work is assessed by reference to its own identity and collection history.

Certificates, serial numbers or comparable verification methods may be used to verify authenticity.

4.10 Technological Neutrality

This Framework is technology-neutral.

Its fundamental principles shall continue to apply as technologies develop, new delivery methods emerge, new file formats are introduced and new collection models are created.

4.11 Verifiability and Evidence

DaDa Design may record electronic transactions for purposes of legal certainty, security, service performance and compliance.

Orders, payments, deliveries, logins and user actions may be verifiable through electronic records to the extent permitted by applicable law.

Electronic records may be used as evidence to the extent legally admissible.

4.12 Data Minimisation

Personal data shall be processed only to the extent necessary for specified, explicit and legitimate purposes.

Data irrelevant to the processing purpose or excessive in relation to that purpose shall not be collected.

4.13 Information Security

DaDa Design shall implement appropriate technical and organisational measures designed to protect personal data, payment-related information handled within its systems and electronic records.

Information security forms an integral part of corporate governance.

4.14 Accountability

DaDa Design aims to maintain records and documentation capable of demonstrating compliance with applicable law in relation to personal-data processing, electronic record systems and user relationships.

4.15 Proportionality

Technical, legal and administrative measures shall be proportionate to the risks they are intended to address.

Security measures shall not unnecessarily restrict user rights.

4.16 Continuity

The Framework is a living document and may be updated in response to legislative changes, technological developments, evolution of the business model and sector requirements.

Updates shall be prepared with due regard to legal certainty, acquired rights where legally applicable and legitimate user expectations.

4.17 Corporate Consistency

All documents forming part of the Framework shall use consistent terminology, definitions, principles of interpretation and legal concepts.

No document should be prepared in a manner that creates an avoidable contradiction with another Framework document.

4.18 User Trust

DaDa Design recognises long-term user trust as an important element of sustainable commercial activity.

Accordingly, transparent communication, fair practices, accurate information and reliable digital-delivery processes are core management principles.

4.19 Continuous Compliance

DaDa Design regards monitoring relevant legal requirements in the jurisdictions in which it operates and updating this Framework where necessary as part of its corporate responsibility.

4.20 General Assessment

The principles in this Section apply throughout the Framework.

Where uncertainty arises in interpreting a contractual provision, these principles shall be taken into account together with the wording, purpose and mandatory legal context of the relevant provision.

They form part of DaDa Design’s corporate legal approach and the foundation of its digital collectible model.

Section 5 — Definitions

5.1 Definitions Relating to the Parties

5.1.1 Framework

“Framework” means this Legal, Compliance & Governance Manual in its entirety.

The Framework, together with all agreements, policies, procedures, information notices, annexes and officially issued future revisions, shall be regarded as one integrated body.

5.1.2 Business

“Business” means TRAFO e.U., an Austrian registered sole proprietorship established and operating under the laws of the Republic of Austria.

TRAFO e.U. is the operator of the DaDa Design brand and the provider of the digital services covered by this Framework.

5.1.3 Brand

“DaDa Design” means the commercial and digital collectible brand operated by TRAFO e.U.

Unless otherwise stated, references to the “Brand” in the Framework mean DaDa Design.

5.1.4 Platform

“Platform” means the services and infrastructure operated for DaDa Design, including:

• the official website;

• customer portal;

• payment infrastructure;

• digital delivery systems;

• certificate-verification system;

• mobile applications;

• API services; and

• other digital services developed in the future.

5.1.5 User

“User” means any natural or legal person who visits or uses the Platform for any purpose.

User status does not require creation of a membership account.

5.1.6 Visitor

“Visitor” means a person who views or accesses the Platform without creating an account.

5.1.7 Member

“Member” means a person who creates a user account on the Platform and accepts the applicable membership terms.

5.1.8 Account Holder

“Account Holder” means the natural or legal person lawfully entitled to the user account created on the Platform.

5.1.9 Buyer

“Buyer” means a natural or legal person who purchases a Digital Collectible Asset through the Platform.

The term Buyer refers to the person’s capacity in the relevant purchase transaction.

5.1.10 Rights Holder

“Rights Holder” means a natural or legal person to whom specified rights are granted under this Framework or an applicable agreement.

The nature and scope of such status depend on the relevant ownership, licence or other legal rights.

5.1.11 Owner

“Owner” means a natural or legal person holding the ownership or other transferable proprietary rights expressly granted in respect of a particular Digital Collectible Asset.

Being the Owner does not, by itself, mean that intellectual-property rights in the underlying work have been transferred.

5.1.12 Author

“Author” means the person who created the relevant Digital Collectible Asset and holds the applicable authorship rights under law.

Where the relevant rights have been created for, assigned to or otherwise lawfully acquired by TRAFO e.U., the applicable economic rights may be held by TRAFO e.U. in accordance with the relevant legal arrangement.

5.1.13 Licensee

“Licensee” means a person or organisation to whom specified usage rights have been granted under a written licence agreement.

Granting a licence does not by itself constitute a complete transfer of ownership or copyright.

5.1.14 Authorised Representative

“Authorised Representative” means a person legally authorised to carry out legal acts on behalf of a natural or legal person.

5.1.15 Third Party

“Third Party” means any natural or legal person other than the Business and the User.

Payment institutions, technical service providers, advisers, auditors and business partners may constitute Third Parties.

5.1.16 Service Provider

“Service Provider” means any person or organisation providing technical, legal, financial or operational support for operation of the Platform.

5.1.17 Payment Service Provider

“Payment Service Provider” means an authorised financial institution or electronic-payment infrastructure used to process payment transactions.

5.1.18 Support Team

“Support Team” means the authorised function designated by the Business to assess user requests, technical issues and complaints.

5.1.19 Administrator

“Administrator” means an authorised person responsible for technical, commercial or legal administration of the Platform.

5.1.20 Competent Authority

“Competent Authority” means courts, administrative bodies and public authorities having powers of supervision, investigation, enforcement or decision-making under applicable law.

5.2 Definitions Relating to the Digital Collectible Ecosystem

5.2.1 Digital Collectible Asset

“Digital Collectible Asset” is the principal legal term used for digital works created or lawfully offered by DaDa Design that have a collectible character.

The term includes unique assets, limited-edition assets and digital assets created under specified production or edition rules.

Digital Collectible Assets are delivered electronically and do not constitute physical goods.

Unless otherwise stated in this Framework, references such as “product”, “work” and “collectible product” in the relevant context refer to a Digital Collectible Asset.

5.2.2 Digital Collectible Product

“Digital Collectible Product” means a digital work within the category of Digital Collectible Assets that may be offered for sale independently.

A Digital Collectible Product may constitute an individual collectible or part of a larger collection series.

5.2.3 Digital Artwork

“Digital Artwork” means a Digital Collectible Asset possessing artistic, aesthetic or design value.

Such works may be created using graphic design, illustration, typography, collage, photo manipulation, AI-assisted creative tools and other digital-art techniques, subject to applicable law and third-party rights.

5.2.4 Collection

“Collection” means a body of Digital Collectible Assets created around a common theme, narrative, design language or concept.

A Collection may consist of a single work, a limited series or several sub-series.

5.2.5 Collection Series

“Collection Series” means a group of works within the same Collection produced according to predetermined rules.

Each series may have an independent edition or production plan.

Examples include:

• Founder Series

• Genesis Series

• Heritage Series

• Anniversary Series

5.2.6 Limited Edition

“Limited Edition” means a group of Digital Collectible Assets for which the edition size is announced in advance and is not intended to be increased thereafter.

The announced edition size is a material element used to preserve the integrity and credibility of the Collection.

5.2.7 Unique Edition

“Unique Edition” means a Digital Collectible Asset created as a single edition.

Such works may be identified as “1/1”.

5.2.8 Open Edition

“Open Edition” means Digital Collectible Assets for which no fixed production quantity has been predetermined and which may be issued in accordance with rules announced by the Business.

Open Editions are not subject to the limited-edition quantity commitment unless expressly stated otherwise.

5.2.9 Edition Number

“Edition Number” means the sequential identifier of a Digital Collectible Asset within a particular Limited Edition.

For example, “03/50” identifies the third item within an edition of fifty.

5.2.10 Collection ID

“Collection ID” means a unique identifier distinguishing a particular Collection from other Collections.

5.2.11 Asset ID

“Asset ID” means the unique system identifier created for each Digital Collectible Asset.

An Asset ID is intended to remain associated with the relevant asset and not to be reassigned to another asset.

5.2.12 Certificate of Authenticity

“Certificate” or “Certificate of Authenticity” means the official digital document recording authenticity, collection information and verification data for a particular Digital Collectible Asset.

The Certificate does not by itself determine the complete scope of ownership or copyright; those matters remain subject to applicable law and the relevant contractual terms.

5.2.13 Certificate Number

“Certificate Number” means the unique verification number assigned to each Certificate.

5.2.14 Authenticity

“Authenticity” means verification that a Digital Collectible Asset originates from, or has been lawfully issued by, DaDa Design and has not been altered in an unauthorised manner within the relevant verification system.

5.2.15 Verification

“Verification” means the process of checking the authenticity or validity of a Digital Collectible Asset or Certificate by appropriate technical and legal methods.

5.2.16 Collection History

“Collection History” means the body of version, certificate and ownership-related information maintained in the system from creation of a Digital Collectible Asset onward, subject to applicable data-protection and record-retention rules.

5.2.17 Ownership Record

“Ownership Record” means an electronic record used to document the person recognised by the Platform as holding the relevant contractual ownership or proprietary rights in a Digital Collectible Asset.

The record may be updated where appropriate and may be used to document a lawful transfer.

5.2.18 Portfolio

“Portfolio” means the Digital Collectible Assets associated with a User or Owner within the relevant system.

5.2.19 Collectible Value

“Collectible Value” means any economic, artistic or cultural value that may change over time according to market conditions, artistic assessment, scarcity or collector interest.

The Business does not guarantee any present or future collectible, resale, investment or market value.

5.2.20 Archived Work

“Archived Work” means a Digital Collectible Asset that is no longer actively offered for sale but remains recorded in the DaDa Design archive.

5.3 Definitions Relating to Intellectual Property and Legal Rights

5.3.1 Intellectual Property

“Intellectual Property” means legally protected economic and moral rights arising from intellectual and creative activity.

For purposes of this Framework, intellectual property includes copyright, design rights, trademark rights, database rights and comparable rights recognised by applicable law.

Unless expressly agreed otherwise in writing, intellectual-property rights remain with TRAFO e.U., the Author or the relevant Rights Holder, as applicable.

5.3.2 Copyright

“Copyright” means the rights conferred by applicable law on the author or rights holder of a Digital Collectible Asset.

Such rights may include reproduction, distribution, adaptation, communication to the public, display and licensing rights, subject to the applicable legal system.

The sale of a Digital Collectible Asset does not, by itself, constitute an assignment of copyright.

5.3.3 Moral Rights

“Moral Rights” means rights protecting the personal relationship between an author and the author’s work.

Depending on applicable law, these may include the right of attribution, protection of the integrity of the work and other legally recognised moral rights.

Moral rights shall be respected to the extent required by applicable law.

5.3.4 Economic Rights

“Economic Rights” means intellectual-property rights relating to economic exploitation of a Digital Collectible Asset or underlying work.

They may include reproduction, distribution, licensing and commercial exploitation rights.

Unless expressly agreed otherwise, such rights remain with the applicable rights holder.

5.3.5 Ownership

“Ownership” means the proprietary or contractual ownership rights expressly granted in relation to a particular Digital Collectible Asset.

Subject to the applicable agreement and mandatory law, an Owner may be entitled to hold, transfer, sell, donate or bequeath those acquired rights.

Ownership of a Digital Collectible Asset does not, by itself, include intellectual-property, copyright, design or trademark rights.

5.3.6 Assignment of Intellectual Property

“Assignment of Intellectual Property” means the complete or partial transfer of copyright or other intellectual-property rights by a legally valid written agreement where such form is required.

Standard purchases made through the Platform do not constitute an assignment of intellectual property unless expressly stated otherwise.

5.3.7 Licence

“Licence” means permission granted by the relevant Rights Holder to exercise specified usage rights subject to specified conditions.

A licence does not by itself constitute a transfer of ownership.

Its scope is limited to the rights expressly granted in the applicable licence terms.

5.3.8 Exclusive Licence

“Exclusive Licence” means a licence under which specified usage rights are granted exclusively to one licensee to the extent expressly agreed.

Any restriction on the Rights Holder’s own use or on licensing to others must be expressly established in the applicable agreement and is subject to mandatory law.

5.3.9 Non-Exclusive Licence

“Non-Exclusive Licence” means a licence under which the same or comparable usage rights may be granted to more than one person.

5.3.10 Commercial Use

“Commercial Use” means use of a Digital Collectible Asset or underlying work for the direct or indirect purpose of obtaining economic benefit.

Examples may include:

• advertising;

• product packaging;

• sales materials;

• brand promotion;

• paid publication;

• licensing; and

• reproduction for resale.

Commercial Use is permitted only to the extent expressly authorised by the applicable terms or by the Rights Holder.

5.3.11 Personal Use

“Personal Use” means use of a Digital Collectible Asset solely for personal, non-commercial collecting or enjoyment, subject to the applicable terms.

It does not include commercial exploitation, income-generating use or licensing rights.

5.3.12 Resale Right

“Resale Right” means any contractual right of an Owner to transfer the acquired Digital Collectible Asset or the rights associated with it to a third party, where such transfer is legally and technically supported.

Such transfer concerns only the transferable rights held by the Owner and does not transfer copyright unless separately and expressly agreed.

5.3.13 Transfer

“Transfer” means the lawful transfer to another person of transferable rights associated with a Digital Collectible Asset.

A transfer may be documented by written, electronic or system records, subject to applicable law.

5.3.14 Trademark

“Trademark” means DaDa Design names, logos, emblems, trade names and other distinctive signs protected or used as commercial identifiers.

Trademark rights are separately protected.

Purchase of a Digital Collectible Asset does not grant a right to use DaDa Design trademarks except as expressly permitted by law or written authorisation.

5.3.15 Derivative Work

“Derivative Work” means a new work created by adapting, transforming or otherwise using a pre-existing Digital Collectible Asset in a manner falling within the exclusive rights of the relevant rights holder.

No Derivative Work may be created where authorisation is legally required unless such authorisation has been granted.

5.3.16 Reproduction

“Reproduction” means copying or reproducing a Digital Collectible Asset by any method.

The right of reproduction is governed by applicable copyright law.

5.3.17 Distribution

“Distribution” means distribution or making available of copies of a Digital Collectible Asset to third parties to the extent governed by applicable intellectual-property law.

5.3.18 Communication to the Public

“Communication to the Public” means making a Digital Collectible Asset available to the public through the internet, digital platforms or other electronic means in circumstances falling within the relevant copyright right.

5.3.19 Design Right

“Design Right” means rights recognised under applicable law in relation to the visual composition, colour arrangement, typography, illustration, character design and aesthetic appearance of a Digital Collectible Asset.

5.4 Commercial and Operational Definitions

5.4.1 Order

“Order” means the electronic purchasing process initiated and completed by a User through the Platform for the purpose of purchasing a particular Digital Collectible Asset.

An Order is formed through the relevant product selection, payment process and acceptance or acknowledgement of the legally required contractual terms and information.

5.4.2 Order ID

“Order ID” means the unique transaction identifier generated by the system for each purchase.

It is used to identify the transaction and trace the relevant transaction history.

5.4.3 Sales Contract

“Sales Contract” means the contract concluded electronically between the Business and the Buyer governing their rights and obligations in connection with the supply or transfer of a Digital Collectible Asset.

5.4.4 Digital Delivery

“Digital Delivery” means making a purchased Digital Collectible Asset electronically accessible to the Buyer.

Delivery may take place through:

• a user account;

• a secure download link;

• email, where applicable;

• a licence or customer portal; or

• other verified digital access methods.

5.4.5 Delivery Date

“Delivery Date” means the date on which the Digital Collectible Asset is first made available to the Buyer in accordance with the applicable delivery process.

The relevant system records may be used to establish this date.

5.4.6 Delivery Status

“Delivery Status” means system information indicating the technical or operational stage of an Order.

Examples include:

• Pending

• Processing

• Delivered

• Cancelled

• Under Review

5.4.7 Invoice

“Invoice” means a sales document issued electronically or by another legally permitted method in accordance with applicable tax law.

5.4.8 Payment

“Payment” means the financial transaction made by the Buyer for the purpose of purchasing a Digital Collectible Asset.

5.4.9 Payment Confirmation

“Payment Confirmation” means electronic confirmation from the Payment Service Provider indicating that a payment has been successfully completed or otherwise reached the status specified by that provider.

5.4.10 Payment Service Provider

“Payment Service Provider” means an authorised financial institution or payment service used to process electronic payment transactions.

5.4.11 Price

“Price” means the amount payable for purchase of a particular Digital Collectible Asset.

Taxes, transaction charges or other amounts shall be disclosed separately where required by law.

5.4.12 Taxes

“Taxes” means value added tax (VAT), sales tax or comparable fiscal charges applicable under the relevant law.

5.4.13 Promotion

“Promotion” means a discount, benefit or special sales arrangement offered for a specified period or campaign.

Promotions do not create a continuing entitlement unless expressly stated.

5.4.14 Discount

“Discount” means a temporary or continuing reduction in the sales price offered subject to specified conditions.

5.4.15 Campaign

“Campaign” means a commercial sales initiative applied to specified products or services for a limited period or under stated conditions.

5.4.16 Coupon

“Coupon” means an electronic code providing a discount or benefit when specified conditions are met.

5.4.17 Gift Code

“Gift Code” means an electronic access or redemption code allowing specified products to be obtained free of charge or at a discount under the applicable conditions.

5.4.18 Cancellation

“Cancellation” means the legally effective termination or cancellation of an Order in accordance with applicable law and the relevant contractual provisions.

5.4.19 Refund

“Refund” means full or partial repayment of the purchase price in accordance with applicable law and the relevant contractual terms.

Specific rules concerning digital content, performance begun at the consumer’s express request and statutory withdrawal rights are governed separately by the applicable consumer-law provisions and contractual notices.

5.4.20 Complaint

“Complaint” means a communication by a User or Rights Holder expressing dissatisfaction concerning a product, service or process.

5.4.21 Technical Support

“Technical Support” means assistance aimed at resolving technical problems arising in connection with delivery, access or use of Digital Collectible Assets.

5.4.22 Support Request

“Support Request” means a formal request submitted by a User to the Platform concerning a technical or administrative matter.

5.4.23 Review Process

“Review Process” means the legal, technical and operational assessment of a request, complaint or dispute.

5.4.24 Dispute

“Dispute” means a legal disagreement arising between the Business and a User in connection with this Framework or an applicable agreement.

5.4.25 Force Majeure

“Force Majeure” means an event beyond the reasonable control of the affected party that prevents or materially impedes performance of obligations, to the extent recognised by applicable law.

Examples may include natural disasters, war, epidemics or pandemics, binding decisions of public authorities, widespread internet outages, cyberattacks and comparable unforeseeable events.

5.4.26 Revision

“Revision” means a content change made to this Framework or a related document.

Each Revision shall be recorded with an appropriate date and version identifier.

5.4.27 Version

“Version” means the officially applicable version of a document at a specified date.

New Versions supersede previous Versions prospectively unless otherwise stated or required by law; they do not retroactively alter concluded transactions unless legally permissible.

5.4.28 Business Day

“Business Day” means a working day in the Republic of Austria other than Saturday, Sunday or an Austrian public holiday relevant to the applicable calculation.

Unless expressly stated otherwise, periods specified in Business Days shall be calculated accordingly.

Section 5 — Definitions

5.5 Technical and Electronic Record Definitions

5.5.1 Electronic Record

“Electronic Record” means any digital data created, stored or processed electronically in relation to transactions or activities carried out on the Platform.

Electronic Records may be used, in accordance with applicable law, for transaction security, provision of services, resolution of disputes and fulfilment of legal obligations.

5.5.2 System Log

“System Log” means technical records automatically generated during operation of the Platform.

System Logs may be retained for troubleshooting, security, performance monitoring and technical audit purposes in accordance with applicable law.

5.5.3 Transaction Record

“Transaction Record” means a system-generated record relating to an Order, Payment, Delivery, membership action or other transaction carried out by a User.

5.5.4 Order Record

“Order Record” means the electronic record containing information associated with creation of an Order, which may include date, time, Order ID, product information and relevant transaction data.

5.5.5 Delivery Record

“Delivery Record” means technical or operational records indicating that a Digital Collectible Asset has been made accessible to the Buyer.

Such records may be created to administer and, where necessary, verify the delivery process.

5.5.6 Download Log

“Download Log” means a system-generated record indicating access to a download link or, where technically recorded, download of a Digital Collectible Asset.

Such records may be used to administer technical processes and review delivery events.

5.5.7 Access Log

“Access Log” means technical records concerning access to the Platform, logins, sessions and related access events.

5.5.8 Authentication Log

“Authentication Log” means system records generated during login or identity/authentication processes associated with a user account.

5.5.9 Session

“Session” means a period of Platform use beginning when a User establishes a session and ending when that session is terminated or expires.

5.5.10 Session ID

“Session ID” means a unique technical identifier used to identify a particular user session.

5.5.11 Device Information

“Device Information” means technical information processed by the system concerning the device used to access the Platform.

Such information may be processed where necessary for security, functionality and service quality and subject to applicable data-protection law.

5.5.12 IP Address

“IP Address” means the network address used by a device for internet communications.

IP addresses may be processed only to the extent necessary and in accordance with applicable data-protection law.

5.5.13 Timestamp

“Timestamp” means a technical record indicating the date and time of a particular electronic event or transaction.

5.5.14 Electronic Evidence

“Electronic Evidence” means electronic records or digital data capable of being used to demonstrate a legally relevant event or transaction to the extent admissible under applicable procedural and evidentiary law.

5.5.15 Electronic Consent

“Electronic Consent” means a declaration, confirmation or consent communicated by electronic means and recorded by the Platform where appropriate.

5.5.16 Explicit Consent

“Explicit Consent” means an affirmative and specific declaration of consent given by a User where applicable law requires an explicit form of consent.

The validity and legal effect of consent are determined under the applicable legal rules.

5.5.17 Checkbox Confirmation

“Checkbox Confirmation” means an affirmative action by which a User selects an unchecked electronic checkbox to acknowledge or accept specified information, terms or a legally relevant declaration.

A checkbox shall not be treated as valid consent where mandatory law requires a different standard or where it has been preselected in circumstances in which active consent is required.

5.5.18 Document Version Record

“Document Version Record” means the electronic record identifying the version of a contractual document, policy, notice or other legal text presented or applicable at a specified time.

5.5.19 Audit Log

“Audit Log” means a structured electronic record created for the purpose of tracing relevant system, administrative or user actions.

Audit Logs may be used for security, compliance, troubleshooting and evidentiary purposes to the extent permitted by law.

5.5.20 Backup

“Backup” means a duplicate copy of data or system information maintained for recovery, continuity or security purposes.

5.5.21 Data Retention Period

“Data Retention Period” means the period for which particular data is retained on the basis of applicable law, contractual necessity, legitimate operational requirements or another valid legal basis.

5.5.22 Data Deletion

“Data Deletion” means deletion, erasure or irreversible removal of data from active systems and, where applicable, from backups in accordance with applicable legal and technical requirements.

5.5.23 Business Continuity

“Business Continuity” means the organisational and technical measures designed to maintain or restore critical services during and following disruptions.

5.5.24 System Incident

“System Incident” means a technical event that adversely affects, or may adversely affect, the availability, integrity, confidentiality, security or proper operation of the Platform.

5.5.25 Technical Maintenance

“Technical Maintenance” means planned or unplanned technical work performed to maintain, repair, update, secure or improve the Platform.

5.6 Security and Compliance Definitions

5.6.1 Information Security

“Information Security” means the organisational and technical measures designed to protect the confidentiality, integrity and availability of information processed by the Business.

5.6.2 Cybersecurity

“Cybersecurity” means measures designed to protect systems, networks, devices and digital data against cyber threats, unauthorised access and malicious activity.

5.6.3 Security Incident

“Security Incident” means an event that compromises or may compromise the confidentiality, integrity or availability of systems, information or services.

5.6.4 Personal Data Breach

“Personal Data Breach” has the meaning assigned to that term under the GDPR and means a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

5.6.5 Risk

“Risk” means the possibility that a legal, technical, operational, security or commercial event may adversely affect the Business, Users, systems or legally protected interests.

5.6.6 Risk Management

“Risk Management” means the systematic process of identifying, assessing, mitigating and monitoring legal, technical, operational and commercial risks.

5.6.7 Compliance

“Compliance” means conduct by the Business in accordance with applicable law, this Framework, internal policies and applicable ethical standards.

Compliance activities are intended to support fulfilment of legal obligations, development of internal processes and preservation of corporate reliability.

5.6.8 Compliance Programme

“Compliance Programme” means the body of policies, procedures, training, controls and review activities established to support fulfilment of the Business’s legal and ethical obligations.

5.6.9 Internal Policy

“Internal Policy” means a written rule or set of operating principles adopted by the Business concerning a specified subject.

Internal Policies may not override applicable mandatory law.

5.6.10 Procedure

“Procedure” means written rules describing how a particular business or operational process is to be carried out.

5.6.11 Corporate Governance

“Corporate Governance” means the Business’s management structure, decision-making processes, allocation of authority, accountability arrangements and internal-control mechanisms.

5.6.12 Internal Control

“Internal Control” means a control mechanism designed to support operation of the Business in accordance with applicable law, internal policies and defined processes.

5.6.13 Review and Internal Audit

“Review and Internal Audit” means periodic legal, technical or operational review of activities and their consistency with this Framework.

Such reviews may be conducted by TRAFO e.U. or persons authorised by it.

The Business may obtain external legal, financial, technical or information-security advice where considered necessary. This provision does not, by itself, create a continuing statutory or independent-audit obligation.

5.6.14 Unauthorised Access

“Unauthorised Access” means access by a person to the Platform, systems or data without the required permission or authority.

5.6.15 Authentication

“Authentication” means a technical or administrative process used to verify a user’s asserted identity or credentials.

5.6.16 Authorisation

“Authorisation” means determination of the systems, data or actions that an authenticated User is permitted to access or perform.

5.6.17 Confidentiality

“Confidentiality” means ensuring that personal data, trade secrets and other protected information are accessible only to persons or systems authorised to access them.

5.6.18 Trade Secret

“Trade Secret” means non-public information, methods, processes or documents that qualify for protection under applicable law and whose unauthorised disclosure may adversely affect the Business’s economic or competitive interests.

5.6.19 Incident Response

“Incident Response” means activities undertaken to identify, assess, contain, manage and mitigate the effects of security or technical incidents.

5.6.20 Business Continuity Plan

“Business Continuity Plan” means documented organisational and technical arrangements designed to maintain or restore critical business functions following a disruption.

5.6.21 Disaster Recovery

“Disaster Recovery” means processes designed to restore systems within a reasonable period following serious technical failures, data loss or other major disruptions.

5.6.22 Fraud

“Fraud” means unlawful misuse of the Platform, payment systems or Digital Collectible Assets for the purpose of obtaining an unlawful financial or other benefit.

5.6.23 Suspicious Transaction

“Suspicious Transaction” means a transaction or behaviour displaying unusual technical, legal or commercial characteristics that reasonably requires additional review.

5.6.24 Identity Theft

“Identity Theft” means unlawful use of another person’s identity or account information without authorisation.

5.6.25 Account Security

“Account Security” means technical and organisational measures designed to protect user accounts against unauthorised access or misuse.

5.6.26 Legal Dispute Management

“Legal Dispute Management” means processes for assessing, recording and resolving legal disputes arising with Users, business partners or Third Parties in accordance with applicable law.

5.6.27 Policy

“Policy” means a high-level written document setting out the Business’s general approach and principal rules concerning a specified subject.

Policies may be supported by procedures and instructions where appropriate.

5.6.28 Continuous Improvement

“Continuous Improvement” means the principle of periodically reviewing and developing the Business’s security, compliance and operational processes.

Section 6 — Document Governance and Hierarchy

6.1 Purpose

The purpose of this Section is to establish common rules for the preparation, implementation, interpretation, updating and governance of agreements, policies, procedures and other documents forming part of the DaDa Design Legal Framework.

6.2 Document Structure

The Framework is composed of interrelated legal and governance documents.

Depending on their purpose, these may include:

• the Master Foundation;

• terms and conditions and other contracts;

• privacy and data-protection documents;

• consumer information and withdrawal notices;

• intellectual-property policies;

• payment and delivery policies;

• internal compliance policies;

• operational procedures;

• security documentation;

• certificates, records and related forms; and

• annexes and future revisions.

Each document shall be interpreted in light of its function and its relationship with the Framework as a whole.

6.3 Document Hierarchy

Unless mandatory law or an expressly applicable specific provision requires otherwise, the documents are interpreted in the following general order:

1. Mandatory provisions of applicable law;

2. Master Foundation;

3. the specific agreement governing the relevant transaction;

4. the specific policy applicable to the subject matter;

5. procedures, instructions and operational documentation.

A more specific valid contractual provision may govern a specific matter over a general Framework provision where legally permissible.

6.4 Joint Interpretation of Documents

Framework documents are intended to complement one another.

No provision should be interpreted in isolation where the context of another applicable Framework document is necessary to determine its proper meaning.

Interpretation shall seek to preserve consistency, legal certainty and compliance with mandatory law.

6.5 Terminology Standard

Terminology used throughout the Framework shall be standardised.

The same concept should not be described by materially inconsistent terms in different documents.

Defined terms such as:

• “Digital Collectible Asset”;

• “Owner”;

• “Rights Holder”;

• “Platform”; and

• “Business”

shall have the same meaning throughout the Framework unless a particular document expressly defines them differently for a legally justified purpose.

6.6 Document Identification

Each official document should contain, where applicable:

• document number;

• document title;

• version number;

• prepared by / responsible function;

• effective date;

• date of last update;

• governing law; and

• document status (Draft / Effective / Archived).

6.7 Revision Management

The Framework is a living body of documentation.

Documents may be updated in response to legislative changes, technological developments, changes in the business model or operational requirements.

Material changes shall be recorded using an appropriate new version number and revision date.

Previous versions may be archived and retained for reference, evidence and compliance purposes in accordance with applicable retention requirements.

6.8 Revision History

Official documents should contain a “Revision History” table where appropriate.

The table should record at least:

• revision number;

• date;

• brief description of the change; and

• approving person or responsible function.

6.9 Document Control

Current official versions of Framework documents shall be issued or designated by the Business.

Outdated or unauthorised copies shall not be treated as the current official version.

6.10 Rule in the Event of Inconsistency

Where an inconsistency or difference of interpretation arises between Framework documents, the Master Foundation, the specific applicable agreement and the relevant policy shall be considered together, subject to the hierarchy in Section 6.3.

Where the inconsistency cannot lawfully be resolved by interpretation, applicable mandatory law shall prevail.

6.11 Responsibility for Document Governance

TRAFO e.U. is responsible for preparation, updating and publication of the Framework.

The Business may obtain advice from external legal, financial or technical specialists where it considers such advice appropriate.

Section 7 — Final Provisions

7.1 Entry into Force

This Framework enters into force on the date on which it is officially published or otherwise designated as effective by the Business.

Agreements and policies issued under the Framework apply from their respective effective dates.

7.2 Amendments

The Business may update this Framework subject to applicable law.

Material amendments shall be communicated before their effective date through the Platform or another appropriate communication method where required by law.

Amendments affecting mandatory consumer rights shall be implemented only in accordance with applicable law.

7.3 Severability

If any provision of this Framework is invalid or unenforceable, the validity of the remaining provisions shall not be affected to the extent permitted by law.

The invalid or unenforceable provision shall be dealt with in accordance with applicable law and, where legally permissible, interpreted or replaced so as to achieve as closely as possible its lawful commercial and legal purpose.

7.4 No Waiver

Failure by the Business to exercise a right in a particular instance does not constitute a permanent waiver of that right unless a waiver is expressly made and legally effective.

7.5 Language Versions

This Framework may be prepared in Turkish, German and English.

If a difference of meaning arises between language versions, the language version officially designated by the Business as controlling shall prevail only to the extent legally permissible and without prejudice to mandatory consumer-protection or transparency requirements.

For an Austrian business, the German version may be designated as the controlling internal reference version where appropriate.

7.6 Governing Law

This Framework and related documents are governed by the laws of the Republic of Austria, except to the extent that mandatory conflict-of-laws rules or mandatory provisions of another applicable legal system require otherwise.

7.7 Competent Courts and Authorities

Jurisdiction and competent administrative authorities shall be determined in accordance with applicable law.

Nothing in this Framework restricts mandatory jurisdictional rights available to consumers under Austrian or European Union law.

7.8 Notices

Notices under this Framework may be provided through the Platform, to a registered email address or by another electronic communication method permitted by applicable law.

7.9 Intellectual Property in the Framework

Unless otherwise stated, the original texts, structure, terminology and documentation system created for this Framework are owned or controlled by TRAFO e.U. to the extent protected by applicable intellectual-property law.

This provision shall be interpreted in accordance with applicable copyright and other intellectual-property legislation.

7.10 Final Provision

This Framework is the principal document establishing the legal infrastructure for services offered under the DaDa Design brand.

All agreements, policies and procedures forming part of the Framework shall be considered together with this Master Foundation.

The purpose of the Framework is not only to support compliance with legal obligations, but also to establish a transparent, sustainable and reliable digital collectible ecosystem designed to protect user rights.