1. Scope and Definitions

1.1 Scope

This B2C Module Addendum ("Addendum") sets forth additional terms and obligations applicable to Clients who use the InFlow AI platform to send automated accounts receivable communications to individual consumers (natural persons), as distinguished from business entities.

1.2 Additional Definitions

• "B2C Module" means the InFlow AI platform features and functionality specifically designed for communications with individual consumers.
• "Consumer" means a natural person who is the recipient of communications sent through the B2C Module, typically an individual debtor.
• "CBUAE" means the Central Bank of the United Arab Emirates.
• "Sender ID" means the registered sender identification used for SMS communications.
• "Quiet Hours" means time periods during which automated communications are restricted, as configured in the platform.

2. Client Responsibilities

By activating and using the B2C Module, the Client represents, warrants, and undertakes that:

2.1 Lawful Basis for Contact

1. The Client has a valid and lawful basis under the UAE PDPL (Federal Decree-Law No. 45/2021, Articles 4–5) and all other applicable laws to contact each Consumer;
2. The Client holds a legitimate, documented, and enforceable debt obligation for each Consumer entered into the platform;
3. The Client has verified the identity of each Consumer and the accuracy of contact information prior to initiating communications;
4. The Client has provided all required privacy notices to Consumers regarding the processing of their personal data.

2.2 Message Content

1. The Client is solely responsible for the content, accuracy, and appropriateness of all messages sent to Consumers through the platform;
2. All messages shall comply with applicable UAE laws, including but not limited to Federal Law No. 5 of 2012 on Combatting Cybercrimes and the UAE Consumer Protection Law;
3. Messages shall not contain false, misleading, threatening, abusive, or harassing language;
4. Messages shall clearly identify the Client as the sender and the nature of the communication;
5. The Client shall not use the platform to contact Consumers regarding disputed debts that are subject to active legal proceedings, unless advised by legal counsel.

2.3 CBUAE Compliance

Where applicable, the Client shall comply with all CBUAE Consumer Protection Standards and regulations, including:

1. Fair treatment of customers and responsible lending/collection practices;
2. Transparency in communication regarding outstanding obligations;
3. Adherence to any applicable codes of conduct for debt collection;
4. Maintaining records of Consumer complaints and resolutions.

2.4 Sender ID Registration

1. The Client shall register and maintain its own Sender ID with the relevant UAE telecommunications authorities (TRA/TDRA) for SMS communications;
2. The Client shall not use InFlow AI's Sender ID or any misleading sender identification;
3. The Client is solely responsible for compliance with all Sender ID registration requirements and regulations.

2.5 WhatsApp Communication Consent

1. The Client shall obtain valid opt-in consent from Consumers before initiating WhatsApp communications, in compliance with Meta's Business Messaging Policy and the UAE PDPL;
2. The Client shall maintain records of such consent and make them available to InFlow AI upon request;
3. The Client shall honour all opt-out requests received through WhatsApp promptly and ensure they are reflected in the platform.

3. InFlow AI Disclaimers

3.1 Technology Provider Status

InFlow AI is a technology platform provider. InFlow AI is NOT a debt collection agency, financial institution, or legal services provider. InFlow AI does not:

1. Determine which Consumers to contact or what debts to pursue;
2. Make decisions regarding the content or timing of individual communications (beyond platform-enforced compliance features);
3. Provide legal, financial, or debt collection advice;
4. Act as a creditor, debt collector, or agent of the Client.

3.2 No Liability for Client Violations

InFlow AI shall not be liable for any loss, damage, claim, fine, penalty, or regulatory action arising from or in connection with:

1. The Client's failure to obtain proper lawful basis or consent for contacting Consumers;
2. Inaccurate, misleading, or unlawful message content authored by the Client;
3. The Client's violation of applicable laws, regulations, or industry standards;
4. Any claims by Consumers arising from the Client's use of the B2C Module.

3.3 Right to Suspend

InFlow AI reserves the right to immediately suspend or restrict the Client's access to the B2C Module, without prior notice, if:

1. InFlow AI receives complaints from Consumers, telecommunications authorities, or regulatory bodies regarding the Client's communications;
2. InFlow AI reasonably believes the Client is using the platform in violation of applicable laws or this Addendum;
3. The Client's activities pose a risk to InFlow AI's reputation, platform integrity, or relationships with Sub-processors (including Meta/WhatsApp, Twilio, or telecommunications operators);
4. InFlow AI is directed to do so by a regulatory authority or court order.

InFlow AI shall notify the Client of any suspension as soon as reasonably practicable, unless prohibited by law.

4. Platform Compliance Features

The InFlow AI B2C Module includes the following built-in compliance features:

4.1 Quiet Hours

Automated communications are restricted during configurable quiet hours (default: 9:00 PM – 8:00 AM local time of the Consumer). The Client may configure quiet hours but may not disable them entirely.

4.2 Frequency Caps

The platform enforces limits on the number of communications sent to a single Consumer within defined time periods to prevent excessive contact. Default limits:

• Maximum 1 SMS per day per Consumer
• Maximum 1 Email per day per Consumer
• Maximum 1 WhatsApp message per day per Consumer
• Maximum 5 total communications per week per Consumer across all channels

Clients may request adjustments within platform-permitted ranges.

4.3 Opt-Out Management

All communications include clear opt-out mechanisms. When a Consumer opts out:

1. The platform immediately ceases all automated communications to that Consumer on the opted-out channel;
2. The opt-out is logged and enforced across all future campaigns;
3. The Client is notified of the opt-out.

4.4 Complaint Tracking

The platform records and tracks all Consumer complaints and responses, providing the Client with reporting necessary for compliance monitoring.

5. Indemnification

5.1 Client Indemnification

The Client shall indemnify, defend, and hold harmless InFlow AI, its officers, directors, employees, and agents from and against any and all claims, damages, losses, costs, liabilities, and expenses (including reasonable legal fees and regulatory fines) arising out of or relating to:

1. The Client's use of the B2C Module;
2. The Client's breach of this Addendum or applicable laws;
3. Any claim by a Consumer relating to communications sent through the platform on behalf of the Client;
4. The Client's failure to obtain required consents, licenses, or registrations;
5. Any regulatory action or investigation initiated as a result of the Client's activities.

5.2 Survival

The indemnification obligations under this Section shall survive the termination or expiration of this Addendum and the ToS.

6. Limitation of Liability

6.1 Exclusion of Liability

To the maximum extent permitted by applicable law, InFlow AI shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from or in connection with the Client's use of the B2C Module, including but not limited to loss of profits, business interruption, loss of data, or reputational damage.

6.2 Cap on Liability

InFlow AI's total aggregate liability under this Addendum shall not exceed the fees paid by the Client for the B2C Module in the 3-month period immediately preceding the event giving rise to the claim.

6.3 Exceptions

Nothing in this Section shall limit liability for fraud, wilful misconduct, or any liability that cannot be excluded or limited under applicable UAE law.

7. Term and Termination

This Addendum takes effect upon the Client's activation of the B2C Module and remains in force for the duration of the Client's subscription to the B2C Module. InFlow AI may terminate this Addendum and disable the B2C Module immediately upon written notice if the Client materially breaches this Addendum and fails to cure such breach within 14 days of notice.

8. General

8.1 Governing Law

This Addendum shall be governed by the laws of the United Arab Emirates.

8.2 Entire Agreement

This Addendum, together with the ToS and any applicable DPA, constitutes the entire agreement between the Parties with respect to the B2C Module.

8.3 Amendments

InFlow AI may amend this Addendum with 30 days' prior written notice. Continued use of the B2C Module after such notice constitutes acceptance.

Acceptance