QONX.AI · Public Offer · SEVEN LUCKS LLP
User Agreement (Terms of Service)
Version: ___Effective date: June 16, 2026БИН: 170940030760
This document is a public offer of SEVEN LUCKS LLP (BIN 170940030760), hereinafter referred to as the "Contractor," represented by Director Yandiyev Zelimkhan Isayevich. The document is addressed to any individual or legal entity (hereinafter "User") and was developed in accordance with the Civil Code of the Republic of Kazakhstan, the Law of the RK "On Personal Data and Their Protection," GDPR (EU 2016/679), EU Consumer Rights Directive 2011/83/EU, EU Digital Content Directive 2019/770, UAE Federal Decree-Law No. 15 of 2020 on Consumer Protection, and UAE Federal Decree-Law No. 45 of 2021 on Personal Data.
1. Terms and Definitions
- •QONX.AI Platform — an AI/LLM and Big Data SaaS web application for international trade analytics and B2B market research, accessible at https://qonx.ai, developed by SEVEN LUCKS LLP. The Platform is provided exclusively through a web interface and is not available in the App Store or Google Play mobile app stores.
- •User — an individual or legal entity registered on the Platform.
- •Consumer — a User who is an individual using the Platform for personal purposes unrelated to business activities.
- •Data Provider — a third party that provides the Contractor under a license agreement with source datasets of international customs statistics, company information, and transportation data.
- •Request — a single query to the AI agent or manual search of the Platform.
- •QonxPoint (QP) — an internal unit for measuring the volume of Platform services. Not a payment instrument, cryptocurrency, or financial instrument.
- •Cooling-Off Period — the 14-day period established by EU Directive 2011/83/EU and applied to EU-resident Consumers.
2. Subject of the Agreement
2.1The Contractor grants the User remote access to the functionality of the QONX.AI Platform via the internet under a simple non-exclusive license, and the User agrees to use the Platform in accordance with this Agreement and pay for access under the selected pricing plan.
2.2This Agreement governs registration, access provision, analytical data generation, payment and refund procedures, the scope of liability of the parties, intellectual property protection, and special conditions for different jurisdictions.
2.3EU-resident Consumers are subject to additional guarantees in Section 13 of this Agreement, which take precedence over other provisions to the extent they conflict with applicable mandatory EU consumer law.
3. Registration and Acceptance
3.1Registration on the Platform is voluntary and is carried out at https://qonx.ai. Upon registration, the User provides: email address; name; authentication data via Google or GitHub (when using the corresponding sign-in method). The registration form may request additional information. The User must be at least 16 (sixteen) years of age; acceptance of the Agreement by a person under 16 is not permitted.
3.2Acceptance of the offer — clicking the "Register" button while simultaneously confirming via separate checkboxes:
- •"I accept the User Agreement and Privacy Policy" (required checkbox);
- •"I agree to receive marketing communications" (optional, may be unchecked);
- •Cookie consent — via a separate Cookie Consent banner on first visit.
3.3The User must provide accurate information and keep their credentials secure. Upon discovering unauthorized access to their account, the User must immediately notify the Contractor at sevenlucks05@gmail.com 3.4Biometric verification is only applied based on a separate explicit consent per GDPR Art. 9; declining it does not restrict access to the core functionality.
4. Trial Period
4.1The Contractor provides a free trial: 1 (one) Request with generation of 1 (one) PDF report.
4.2After the limit is exhausted, further use requires payment for a Pricing Plan.
4.3The trial period is not counted toward the Cooling-Off Period for EU-resident Consumers — the 14-day period begins from the first paid activation.
5. Pricing and Payment Procedures
5.1Pricing changes. The Contractor may change the pricing of Pricing Plans with at least 30 (thirty) days' notice to the User by email and in the Personal Account. The change applies only to new billing periods; the User may cancel without penalty. Changes to pricing do not affect the already-paid billing period.
5.2Payment methods:
- •Web (individuals and legal entities): payment by credit/debit card and other supported methods is processed through the Paddle payment system (including recurring payments). Paddle acts as an international Merchant of Record; Paddle's payment processing rules apply in parallel with this Agreement.
- •Legal entities: bank transfer payment directly to the Contractor is also available. Invoice requests should be sent to: sevenlucks05@gmail.com
5.3Currency: KZT, USD, EUR — depending on the User's region and payment gateway settings.
5.4Automatic renewal. By enabling automatic renewal, the User consents to regular charges through the Paddle system. Subscription cancellation is done by the User at least 24 hours before the next charge date in the Personal Account at https://qonx.ai or by request at sevenlucks05@gmail.com 6. QonxPoint System
6.1QonxPoint (QP) — an internal unit for measuring service volume. Not electronic money, cryptocurrency, or a financial instrument.
6.2Operation costs: 1 standard AI Request = 1 QP; Company PDF report = 5 QP; API requests — per the pricing grid. Detailed QonxPoint operation pricing is available at https://qonx.ai/pricing and is an integral part of this Agreement. The Contractor may change the operation pricing with at least 30 (thirty) days' notice to the User. 6.3Validity of purchased QP (packages) — 12 months. After expiration — unused QP expire without compensation, unless otherwise stated in the package terms.
6.4Unused subscription QP are not carried over to the next period.
6.5Refund of remaining QP from prepaid packages (not included in subscription) — upon written request to sevenlucks05@gmail.com minus transaction costs. 6.6Bonus QP (promotions, promo codes) have no monetary equivalent and are non-refundable.
7. Refund Policy
7A. For Individual Consumers (B2C)
7A.1Cooling-Off Period. The Consumer may withdraw from the agreement within 14 (fourteen) days of the first payment without giving reasons — provided 0 (zero) Requests have been used.
7A.2If the Consumer made at least one Request during the Cooling-Off Period, they explicitly confirm at registration (via a separate checkbox): "I understand that starting to use the service means the contract has begun to be performed; a refund is calculated proportionally to the unused portion of the period."
7A.3Refunds for technical failures are processed pursuant to Section 10.5 (SLA).
7A.4Refunds for payments made through Paddle are subject to Paddle's refund policy and this Agreement.
7B. For Legal Entities (B2B)
7B.1Refunds are only available for complete non-use of the subscription (0 Requests), upon written request to sevenlucks05@gmail.com, minus transaction costs. 7B.2Once at least one Request has been made, the Contractor's obligations are deemed fulfilled in the corresponding part; no refund is issued — except for SLA violations (Section 10.5).
8. Usage Limits and Service Delivery
8.1Each Pricing Plan contains fixed Request limits per billing period.
8.2When the limit is exhausted, access to the AI agent is blocked until the next period or until a QP package is purchased.
8.3Unused Requests under a subscription are not carried over to the next period and are not compensated.
8.4Plan changes (upgrade / downgrade). When upgrading, the new plan is activated immediately; the unused paid period balance is credited proportionally. When downgrading, the change takes effect at the start of the next billing period. The accumulated QonxPoints balance (both prepaid packages and subscription QP) is fully preserved upon any plan change.
8.5Concurrent sessions. Use of a single account on two or more devices simultaneously is prohibited. If concurrent sessions are detected, the Platform may automatically terminate older sessions. Systematic violation is grounds for account blocking.
9. Intellectual Property and Prohibition of Misuse
9.1The Contractor holds exclusive rights to: the web application source code, AI algorithms, analytics methodology, interface design, report formats and templates.
9.2Important distinction. The underlying trade data is provided to the Contractor under license by third parties (Data Providers). Rights to the primary data belong to the respective rights holders. The User uses analytical materials strictly within the scope of this Agreement.
9.3The User is granted a limited, revocable, non-exclusive, non-transferable right to use the Platform exclusively for their own internal business purposes, without the right to resell, sublicense, or publicly distribute.
9.4Prohibited (Platform misuse):
- •mass distribution or resale of reports;
- •automated scraping and data downloading;
- •decompilation and reverse engineering;
- •sharing a single account among multiple individuals (outside corporate plans);
- •using a VPN or other proxy means to circumvent Platform geographic restrictions;
- •creating multiple accounts by one person (multi-accounting), including to circumvent free plan limits or abuse referral programs;
- •using a single account on two or more devices simultaneously;
- •using any automated scripts, software tools, robots, spiders, or browser automation tools (including but not limited to: Selenium, Puppeteer, Playwright) to interact with the Platform UI;
- •DoS/DDoS attacks and stress testing of Platform servers without the Contractor's written consent;
- •using automated vulnerability scanning tools without the Contractor's consent;
- •circumventing protection systems (WAF, Anti-Bot, CAPTCHA, Rate Limit, Cloudflare, and similar) by any means;
- •uploading files containing malicious code;
- •commercial resale or sublicensing of Platform access to third parties;
- •initiating unjustified chargeback disputes (chargeback fraud);
- •using the Platform to reproduce, map, or reverse engineer the Data Providers' database through systematic queries.
9.5Violation of Section 9.4: account blocking without refund; fine of up to 12× the annual plan cost (proportional to actual damage); User's right to challenge the restriction within 30 days at sevenlucks05@gmail.com with supporting evidence. 9.6IP of requests and reports. Text prompts entered by the User remain the User's property. Analytical reports generated by the Platform are the result of the Contractor's software. The User receives the right to use generated reports for their own internal purposes. Exclusive rights to the methodology, algorithms, and report formats are retained by the Contractor.
10. Liability and Limitations (Disclaimer)
10.1"AS IS" Principle. The Platform is provided "as is." The Contractor does not guarantee that the Platform meets all of the User's subjective expectations.
10.2Informational nature of data. All QONX.AI analytical reports, data, and materials are intended exclusively for informational purposes and do not constitute legal, financial, investment, or tax advice. The User independently bears the risk of making decisions based on Platform analytics.
10.3. Data Gaps Due to Provider Limitations
The QONX.AI Platform operates on licensed data received from independent Data Providers — third parties specializing in collecting and aggregating international customs statistics. The Contractor is not the primary data source, does not generate original customs records, and does not control the volume, completeness, composition, or timeliness of data provision by the Provider.
10.3.1. Root cause: why data may be incomplete
- •National trade confidentiality laws: certain countries (including Russia, China, and some EU countries) classify or restrict the transfer of some customs data.
- •Incomplete data transfer by the Provider: some records may reach the Platform later than the customs clearance date or not at all.
- •Technical structure of customs declarations: in some countries, certain declaration fields are optional.
- •Different accounting methodologies: different countries use different HS codes, declaration formats, and standards.
10.3.2. Typical types of missing data
| Data type | Examples of queries where gaps occur |
|---|
| Departure port / destination port | Import of wheat flour from Russia — the dispatch port may not be stated in Russian customs data |
| Country of destination / country of origin | Transit shipments through third countries may not reflect the final recipient |
| Declared goods value | Some jurisdictions do not publish value data by default |
| Cargo weight and volume | Non-standard units of measurement may not convert to a unified format |
| Shipper / consignee name | Data may be anonymized by the source for trade secret purposes |
| HS code / commodity code | Outdated or non-standard classifiers of individual countries |
| Mode of transport and vehicle name | Road transport in some countries is registered without specifying the vehicle |
| Frequency and number of shipments | Provider's aggregated data may not cover 100% of operations for the period |
| Transit port data | Intermediate port data is not available for all routes |
10.3.3Illustrative example. When querying data on imports of wheat flour from Russia (HS code 1101) for any period, the QONX.AI system may display analytical data with one or more fields missing. This is not a Platform error or software defect — these fields were not transmitted by the Data Provider.
10.3.4Data timeliness. Data is received from Providers with a delay of several days to several weeks depending on the source country. The Contractor is not liable for analytical data discrepancies with the current market situation at the time of the Request.
10.3.5Explicit disclaimer. The User confirms and warrants that: (a) they are aware that data may be incomplete due to objective limitations; (b) the incompleteness or inaccuracy of individual fields is NOT a Platform defect or grounds for claims; (c) the User may not make claims against the Contractor for business decisions made based on incomplete data; (d) before making significant decisions, the User independently verifies critical information from official primary sources; (e) the Contractor provides an information analytics tool, not a data completeness guarantee.
10.3.6The Contractor makes reasonable technical efforts to display visual indicators ("no data," "not specified," "data unavailable from provider") in the Platform interface.
10.3.7The provisions of Section 10.3 apply to Users from all countries, including residents of the EU, UAE, USA, and other states.
10.4Feature changes. The Contractor may change or suspend individual Platform features. Users are notified 14 days in advance of changes that materially affect core functionality.
10.5SLA (availability level). Target Uptime — at least 99% per month. Scheduled maintenance — no more than 4 hours/month, with 24-hour advance notice. If SLA is violated, the User may request a proportional recalculation or subscription extension.
10.6Third-party dependency. Failures of payment systems and Data Providers beyond the Contractor's reasonable control are classified as force majeure. The Contractor may change or discontinue certain data categories upon changes from Providers, with at least 14 days' notice to the User.
10.7Limitation of liability. The Contractor's aggregate liability is limited to the User's payments over the last 12 (twelve) months. This limitation does not apply in cases of the Contractor's willful misconduct or gross negligence, breach of personal data protection obligations, or harm to life or health.
10.8Indirect damages. The Contractor is not liable for indirect damages, lost profits, or reputational harm — to the extent permitted by applicable law. EU-resident Consumers retain rights under Directive 2019/770/EU.
10.9AI response disclaimer. AI agent responses are generated automatically based on language models and may contain inaccuracies or "hallucinations." The Platform is not liable for decisions made based on AI data interpretation.
10.10Use of exported PDF reports. Analytical reports are intended exclusively for the User's internal use. Resale, commercial distribution, and public publication of reports to third parties are strictly prohibited.
10.11QonxPoint refund on technical error. QonxPoints are deducted only after a Request is successfully completed. In case of a technical failure, QonxPoints are not deducted or are automatically returned. Disputed cases are reviewed upon request at sevenlucks05@gmail.com 10.12Data breach notification. In case of a security breach, the Contractor undertakes to: notify the Kazakh Ministry of Digital Development within 1 business day; notify the EU supervisory authority within 72 hours (GDPR Art. 33); notify affected Users by email within 72 hours if the breach creates a high risk to their rights.
11. Personal Data and Storage
11.1Personal data processing — in accordance with the QONX.AI Privacy Policy, which is an integral part of this Agreement. 11.2EU/EEA residents: GDPR (2016/679). UK residents: UK GDPR. Swiss residents: nDSG. UAE residents: UAE PDPL (Decree-Law No. 45 of 2021). Inquiries: sevenlucks05@gmail.com 11.3Consent to marketing communications is given via a separate checkbox at registration and may be revoked at any time through the Personal Account or at sevenlucks05@gmail.com 11.4Request and conversation history with AI. The Platform stores the history of User Requests and conversations with the AI agent. Regarding request history data: (a) authorized QONX team employees may access history exclusively for technical support and violation investigations; (b) anonymized request data may be used for product improvement — in a form that does not allow identification of a specific User; (c) the User may independently delete individual conversations or the entire history in the Personal Account or upon request at sevenlucks05@gmail.com 11.5Data storage location. Personal data is stored on secured servers located in the USA. Transfer of EU residents' data is carried out on the basis of EU Standard Contractual Clauses (SCC). More details — in the Privacy Policy. 12. Force Majeure
12.1The Parties are released from liability for failure to perform obligations due to force majeure circumstances: natural disasters, wars, sanctions, cyberattacks, cloud infrastructure outages, government actions, and full or partial termination of data transfer by the Provider.
12.2Termination or restriction by the Data Provider of certain data transfers due to changes in source country legislation or Provider commercial terms is classified as a force majeure circumstance.
12.3A Party invoking force majeure shall notify the other party within 5 business days of its occurrence.
13. Special Provisions for International Markets
13.1. EU, EEA, and UK Users
13.1.1This section applies to Consumers who are residents of EU Member States, EEA, or the United Kingdom, and takes precedence over other provisions of the Agreement to the extent they conflict with applicable mandatory EU consumer law.
13.1.2Right of withdrawal (Directive 2011/83/EU). The Consumer may withdraw from the contract within 14 days without giving reasons. If the service is used during the Cooling-Off Period, a proportional refund is issued (Section 7A.2).
13.1.3Digital content (Directive 2019/770/EU). QONX.AI is a digital service. Section 10.3 provisions limit liability for third-party data gaps and do not imply a reduction in the quality standards of the Contractor's own software product.
13.1.4Fair terms (Directive 93/13/EEC). Provisions deemed unfair under applicable EU law do not apply to EU-resident Consumers. The arbitration clause does not apply to consumer disputes with EU residents.
13.1.6Right to damages for violations (GDPR Art. 82). If the Contractor breaches its personal data protection obligations, EU-resident Consumers may claim actual damages regardless of Section 10.7 limitations.
13.1.7EU Representative. The Contractor undertakes to appoint an EU Representative before actively engaging with a European audience (GDPR Art. 27). Contact details will be published at qonx.ai/privacy. 13.2. UAE Users
13.2.1This section applies to Users — residents and legal entities of the UAE.
13.2.2Personal data is processed in accordance with UAE Federal Decree-Law No. 45 of 2021 (PDPL UAE). User rights: access, correction, deletion of data — request at sevenlucks05@gmail.com 13.2.3Legal relations are governed with consideration of UAE Consumer Protection Law (Federal Law No. 15 of 2020). UAE consumers may apply to the UAE Ministry of Economy (Consumer Protection Department).
13.2.4The data disclaimer (Section 10.3) applies to UAE Users in full.
13.2.5B2B disputes with UAE Users — to IAC arbitration at AIFC Astana. Consumer rights of individuals from the UAE are preserved. Contact: sevenlucks05@gmail.com 13.3. Other International Users
13.3.1Provisions that conflict with the applicable mandatory national laws of the User's country do not apply in the corresponding part.
13.3.2The Contractor does not restrict the inalienable consumer rights provided by their national laws.
14. Dispute Resolution and Applicable Law
14.1Applicable law — the legislation of the Republic of Kazakhstan. If the User's country's mandatory legislation provides additional guarantees, they apply in parallel.
14.3Disputes from RK and CIS residents — to a state court in Astana.
14.4B2B disputes with non-CIS foreign residents (including EU and UAE) — to the International Arbitration Centre at AIFC Astana (1 arbitrator, Astana, language — Russian, final and binding).
14.5Consumers (individuals) retain the right to apply to courts at their place of residence. Arbitration clause 14.4 does not apply to consumer disputes.
14.6EU/EEA/UK residents: may use the EU ODR Platform and national consumer protection authorities.
14.7UAE residents: may apply to the UAE Ministry of Economy (Consumer Protection Department).
15. Contractor Details and Contact Information