Pango Neuro Terms of Service

These Terms of Service (these "Terms") govern access to and use of the AI marketing and advertising assistant service "Pango Neuro" (the "Service") provided by Pango GY Co., Ltd. (the "Company"), a company incorporated under the laws of the Republic of Korea. These Terms apply when you accept them during sign-up or continued use of the Service.

Please read these Terms carefully before using the Service. By creating an account or using the Service, you agree to be bound by these Terms.

Chapter 1. General Provisions

Article 1 (Purpose and Acceptance)

1. These Terms set out the conditions and procedures for using the Service and the rights, obligations, and responsibilities between the Company and each User.
2. These Terms constitute a binding service use agreement between the Company and the User. Agreeing to these Terms and using the Service has the same legal effect as executing a separate written agreement with the Company.
3. If you use the Service on behalf of a company or other legal entity, you represent that you have authority to bind that entity, and "User" refers to that entity.

Article 2 (Definitions)

The terms used in these Terms are defined as follows.

Article 3 (Effect and Amendment of the Terms)

1. These Terms apply to every User who accepts them during sign-up or continued use of the Service.
2. The Company may amend these Terms to the extent that the amendment does not violate applicable law.
3. When the Company amends these Terms, the Company shall give notice by email or within the Service at least 7 days before the effective date, or at least 30 days before the effective date if the amendment is unfavorable to Users.
4. If the User continues to use the Service after the effective date of the amended Terms, the User is deemed to have agreed to the amended Terms.
5. If the User does not agree to the amended Terms, the User may stop using the Service and close the User's account.
6. The Company shall make the current Terms available on its website or through a linked legal page. If a change materially affects a User's rights or obligations, the Company shall also give individual notice by email or within the Service.
7. A separate written agreement between the Company and the User prevails over these Terms to the extent of a conflict. Provisions that by their nature should survive termination remain effective after the service use agreement ends.

Chapter 2. Use of the Service

Article 4 (Description of the Service)

1. The Service is provided primarily by connecting the Service to the User's own AI Client via MCP. The Company's web console is provided for account creation, advertising platform connection, Workspace management, and subscription management.
2. The main areas of the Service are as follows. The specific features available may vary by region and subscription plan.

3. Certain features of the Service (such as the Korean web chat agent) may be available only to Users in specific regions or under specific plans.

Article 5 (Account Registration and Eligibility)

1. A service use agreement is formed when the User agrees to these Terms and the Privacy Policy, completes the sign-up procedure, and the account is created.
2. To use the Service, the User must be at least 18 years old and must use the Service for business purposes.
3. The User shall provide accurate and current information during registration and keep it up to date. The Company may refuse registration or terminate the agreement after the fact in any of the following cases.

• Where the User provides false information or uses another person's information
• Where the User does not meet the eligibility requirements in this Article
• Where the User's use was previously restricted for a violation of these Terms
• Where fees remain unpaid or the User has a history of materially improper use
• Where the intended use is unlawful, fraudulent, or reasonably likely to interfere with the Service or another user's use
• Where the User otherwise fails to meet requirements reasonably established by the Company

4. The Company may defer acceptance where capacity, security, technical, or operational constraints prevent reliable provision of the Service, and shall notify the applicant where reasonably practicable.
5. The User is responsible for safeguarding account credentials and for all use by its Administrators and Members. The User shall not permit credentials to be shared, and shall promptly notify the Company of suspected theft, compromise, or unauthorized use.
6. Administrators are responsible for keeping Member access and permissions current, including promptly revoking or reassigning access when a Member's role changes or ends.

Article 6 (User Obligations and Review Responsibility)

1. The User shall not engage in any of the following acts.

• Misappropriating or fraudulently using another person's account information
• Collecting, storing, disclosing, or using another person's personal data without a lawful basis
• Generating unethical content such as deepfakes, hate speech, or the spread of false information
• Generating or distributing unlawful marketing content such as fraud, gambling, or obscene material
• Defaming another person or intentionally infringing another person's intellectual property rights
• Interfering with the stable operation of the Service, including hacking, distributing malware, unauthorized crawling, abnormal traffic, or attempts to bypass usage or security limits
• Copying, modifying, selling, lending, sublicensing, reverse engineering, decompiling, disassembling, or attempting to extract source code from the Service except where applicable law expressly permits it
• Attempting to extract the Service's AI models, prompts, or system instructions (model or prompt extraction)
• Reselling, assigning, sharing, or otherwise permitting a third party to use an account or contractual position without the Company's prior written consent
• Impersonating the Company, its personnel, another User, or any third party
• Using the Service to discriminate, threaten, abuse, or encourage unlawful prejudice against a person or group
• Submitting national identification numbers or other government-issued identifiers, or special categories of personal data, into prompts or other Input
• Concealing or altering the fact that content was generated by AI in order to deceive a third party
• Any other act prohibited by applicable law or these Terms

2. Before executing any advertising or marketing based on campaign settings, operations, or Output performed through the Service, the User shall independently verify the underlying facts and review compliance with the laws applicable to the User's business and target markets (including advertising and labeling regulations), and shall acknowledge and confirm that certain products or settings may not be supported.
3. If the User uses the Service on behalf of a client (including as an Agency), the User represents and warrants that the User has obtained all rights, consents, and authorizations from that client that are necessary for the use of the Service (including AI analysis, data processing, and the processing described in Article 12), and the User shall indemnify and hold the Company harmless from any claims by the client or third parties arising from the User's failure to obtain them.
4. The User is responsible for ensuring that its Administrators and Members comply with these Terms. Their acts and omissions within the User's account are treated as acts and omissions of the User.
5. The User shall maintain reasonable security controls for its own systems and devices and shall keep independent backups of data needed for its business. The Company is not responsible for loss caused by the User's failure to maintain those controls or backups, except to the extent liability cannot be excluded by law.

Article 7 (Company Obligations)

1. The Company shall use its best efforts to provide the Service in a stable manner.
2. The Company shall protect Users' personal data in accordance with applicable law and the Privacy Policy.
3. The Company shall handle legitimate opinions or complaints raised by Users in good faith.

Chapter 3. Intellectual Property and Confidentiality

Article 8 (Ownership of Input)

1. Ownership of, and intellectual property rights in, the Input that the User provides to the Service belong to the User.
2. The User grants the Company a worldwide, non-exclusive, royalty-free license to reproduce, store, process, adapt, and transmit Input and Output solely for the purposes of (i) providing and operating the Service; (ii) incident response and security; and (iii) improving the quality and performance of the Service and its AI features, including the generation of Pseudonymized Training Data under Article 12 and the training, fine-tuning, and evaluation of AI models developed and operated by the Company. The Company shall not use Input or Output for any purpose other than those set out in these Terms.
3. With respect to opinions, suggestions, and ideas that the User provides to the Company ("Feedback"), the Company may freely use and incorporate them without any obligation of confidentiality or payment, and rights in the resulting work belong to the Company.
4. The User warrants that the User holds lawful rights to any third-party data included in the Input.

Article 9 (Ownership and Limitations of Output)

1. Copyright in, and the right to commercial use of, Output generated through the Service belong to the User in principle.
2. However, due to the nature of generative AI technology, the Company does not guarantee any of the following with respect to Output.

• Originality under copyright law or eligibility for legal registration
• Exclusivity, meaning that similar output will not be generated for other users
• Factual accuracy or legal suitability of the Output

3. Intellectual property rights in the UI, software, algorithms, and other materials created by the Company within the Service belong to the Company.
4. The User shall not commercially reproduce, distribute, or modify the Service, or provide derivative services based on the Service, without the Company's prior consent.
5. The Company makes no warranty as to the accuracy, completeness, or legality of Output or any specific marketing performance.

Article 10 (AI Content Disclosure and Transparency)

1. To ensure transparency, the Company may include metadata in Output indicating that the content was generated by AI.
2. The User shall not conceal or alter the fact that Output was generated by AI in order to deceive a third party.
3. When using AI-generated advertising content, the User shall comply with any disclosure obligations required by applicable law.

Article 11 (Confidentiality)

1. Neither party shall disclose to a third party, or use for any purpose other than this agreement, the other party's trade secrets or technical information learned in connection with the use of the Service.
2. This confidentiality obligation remains in effect for 3 years after the end of the User's use of the Service.

Chapter 4. Data Security

Article 12 (Data Security, Third-Party Model Training, and Service Improvement)

1. The Company shall keep the User's data strictly confidential and shall not provide Input or Output submitted to the Service as training data for public or general-purpose AI models operated by third parties. Matters concerning AI models developed and operated by the Company itself are governed by paragraph 7 of this Article.
2. The Company logically isolates each User's data and shall not expose it to third parties except where compelled by law.
3. When using generative AI engines (such as those of OpenAI, Anthropic, xAI, or Google), the Company uses enterprise or API environments under which user data is not used for the provider's model training without the Company's explicit permission.
4. If the User uploads a third party's personal data to the Service, the Company processes that data only within the scope of the User's instructions as a processor, in accordance with the Privacy Policy and applicable data protection law. Where the User acts on behalf of a client, the User shall ensure that the processing described in this Article, including paragraph 7, is permitted under its arrangements with that client.
5. The Company may monitor use of the Service to the extent reasonably necessary to maintain security, diagnose incidents, respond to support requests, verify the quality of AI responses, detect and block AI security threats such as prompt injection and jailbreak attempts, analyze user experience, enforce these Terms, and improve reliability. This does not create a general duty to monitor User activity. The categories of data collected for this purpose, the processors involved, international transfers, and how to object are set out in the Privacy Policy.
6. The Company grants no right, and claims none, beyond the following: the User grants the Company a limited, non-exclusive right to host, copy, transmit, modify solely for technical formatting, and otherwise process User Data only as necessary to provide, secure, support, and maintain the Service, to carry out paragraph 7, or to comply with law. This right ends when the relevant data is deleted, except where retention is legally required or where the data has been converted into Pseudonymized Training Data in accordance with paragraph 7.
7. (Use of data for AI model training and service improvement) The following applies to AI models developed and operated by the Company.
   1. To improve service quality and advance the Service's AI features, the Company may use Pseudonymized Training Data composed from Usage Data for the training, fine-tuning, evaluation, and performance improvement of AI models developed and operated by the Company.
   2. (Separation of original content and pseudonymized data) The Company stores Original Service Content separately from Pseudonymized Training Data. What is used for training is not Original Service Content but Pseudonymized Training Data, created by removing from the original, or replacing with substitute values, personally identifying information and information capable of identifying a User, an Administrator, a Member, or an advertiser. The Company does not use Original Service Content that has not undergone pseudonymization as training data.
   3. (Pseudonymization method) Identifiers for users, organizations, and Workspaces contained in usage records are replaced with arbitrary identifiers using irreversible methods such as key-based one-way functions. Where mapping information to the original identifiers is generated, it is stored in a separate repository with segregated and minimized access rights. For unstructured data freely entered by the User, personally identifying information such as names, email addresses, contact details, and account identifiers, together with information capable of identifying a User or advertiser, is removed before the derived data is composed.
   4. (Scope) This paragraph applies to the Service's AI analysis and conversational features, automatically executing features such as scheduled tasks, report and material generation features, and tool execution through an AI Client connected by the User via MCP. The detailed scope is as separately notified by the Company within the Service, and the Company may adjust or expand it in stages, giving notice within the Service.
   5. (Excluded data) Data for which use for AI model training or improvement is restricted under a third party's API terms or policies is excluded from this paragraph. In particular, data obtained through Google Workspace APIs (such as Google Sheets, Google Docs, and Google Drive) is not used or transferred to develop, train, or improve AI or ML models — including data aggregated, anonymized, or derived from it — and is not generated into Pseudonymized Training Data. Data obtained through other Google APIs is not used to train or improve generalized or non-personalized models applied in common across other users or organizations, and is used only to provide and improve the Service for the relevant User and organization.
   6. (Deletion) Where the User requests deletion of conversation history or closes its account, the Company destroys the relevant Original Service Content and any identifier mapping information without undue delay. Pseudonymized Training Data from which specific individuals can no longer be identified is not subject to deletion requests, and the Privacy Policy explains how this interacts with the User's rights under applicable data protection law.
   7. (Objection) The User may object to the use described in this paragraph at any time through the settings within the Service or at [email protected]. Following an objection, the Company will not generate Pseudonymized Training Data from data generated thereafter. Data already pseudonymized before the objection is not subject to recall. Objecting places no restriction on the User's use of the Service.
   8. (Ownership and safeguards) All rights in AI models trained or improved under this paragraph and in their outputs belong to the Company. The Company applies the technical measures necessary to ensure that a particular User's Input and Output are not exposed to other users in their original form.

Chapter 5. Nature of AI Services and Responsibility

Article 13 (Nature and Limitations of AI Services)

1. Output generated by the AI features of the Service may have the following limitations inherent to AI technology.

2. Output must be used for reference purposes only, and the User is responsible for all final decisions based on the Output.
3. The quality and behavior of the User's AI Client are governed by the terms of the relevant AI service provider, and the Company is not responsible for the AI Client itself.
4. The Service may use third-party AI APIs provided by OpenAI, Anthropic, xAI, Google, and other AI providers. Their applicable business terms, usage policies, availability, and technical limits may change, and related models or features may accordingly be changed, restricted, or discontinued.
5. The Company may perform automated monitoring and filtering of AI inputs and outputs in order to detect and block prompt injection, jailbreak attempts, malicious input, and attempts to generate policy-violating content. As a result, some legitimate requests may be blocked or responses limited, and the User may object through the support channel within the Service.

Article 14 (Linked Platforms)

1. The Service connects to external advertising platforms such as Google Ads and Meta Ads through APIs.
2. Some campaign setup and operation features may not be available due to API limitations of Linked Platforms, policy changes, or the technical characteristics of specific advertising products.
3. The Company is not responsible for Service limitations caused by policy changes, system failures, or API restrictions of Linked Platforms.
4. The User shall comply with the separate terms of service of each Linked Platform.
5. Advertising costs and other charges incurred on Linked Platforms are payable by the User directly to the relevant platform and are separate from the Service fees.
6. The User may disconnect a Linked Platform at any time. Disconnection stops the Service's future access through the revoked connection, subject to the platform's revocation process and any data retention required by law.
7. The User is responsible for complying with the policies applicable to each Linked Platform it uses, including the following as applicable:

8. The User acknowledges that Linked Platforms may apply their own budget, delivery, invalid-traffic, credit, and compensation rules. The Company does not guarantee that a Linked Platform will issue a credit or other remedy, but will reasonably cooperate with an investigation where the Service may be relevant.

Chapter 6. Fees, Billing, and Refunds

Article 15 (Fees and Payment)

1. The Service is operated on a prepaid subscription basis. Fees and billing standards follow the subscription pricing displayed at the time of purchase.
2. Where Paddle is identified at checkout, our order process is conducted by our online reseller Paddle.com. Paddle.com is the Merchant of Record for those orders, provides payment-related customer service, and handles returns.
3. Payments are subject to the Paddle Checkout Buyer Terms (available at https://www.paddle.com/legal/buyer-terms) in addition to these Terms. Applicable taxes (such as VAT, GST, or sales tax) are determined, collected, and remitted by Paddle based on the User's location.
4. Fees for the User's own AI Client (such as ChatGPT, Claude, or Grok subscriptions or API usage) are not included in the Service fees and are payable by the User directly to the relevant AI service provider.
5. The Company may change subscription prices. Price changes take effect from the next billing cycle, and the Company shall provide advance notice of material price increases in accordance with applicable law.
6. The Company may offer promotions such as discounts or extended access subject to stated eligibility conditions. Promotional benefits do not apply where those conditions are not met.
7. If payment is overdue, declined, reversed, or otherwise not completed, the Company may restrict paid features after any notice or cure period required by applicable law. The Company may add, remove, or change payment methods with reasonable advance notice where practicable.

Article 16 (Auto-Renewal, Free Trials, and Cancellation)

1. Subscriptions renew automatically at the end of each billing period until cancelled.
2. The User may cancel a subscription at any time, with effect from the end of the current billing period. After cancellation takes effect, no further charges are made, and the User may continue to use the Service until the end of the period already paid for.
3. The Company may offer a free trial. Unless the User cancels before the end of the trial period, the paid subscription begins automatically when the trial ends.

Article 17 (Refund Policy)

1. The User may request a full refund of a subscription fee within 14 days of the payment date, provided that the paid features of the Service (including MCP tool calls and AI analysis) have not been substantially used during that period.
2. Once paid features of the Service have been used after payment, the subscription fee for the relevant billing period is in principle non-refundable, given the nature of digital services, except as otherwise required by applicable law.
3. Refunds are processed through Paddle as the Merchant of Record. Refund requests may be submitted to the Company ([email protected]) or to Paddle.
4. If the User is a consumer in a jurisdiction that grants mandatory withdrawal or cancellation rights (including the EU, EEA, and UK 14-day withdrawal right for distance contracts), nothing in this Article limits those statutory rights. Where the User has requested immediate access to the Service, a proportionate deduction may apply for the service already provided, to the extent permitted by law.
5. Nothing in these Terms affects consumer rights that cannot be excluded or limited under the mandatory laws of the User's country of residence.

Chapter 7. Suspension and Termination of the Service

Article 18 (Service Interruption)

1. The Company may temporarily suspend all or part of the Service for any of the following reasons.

• System inspection, replacement, or repair
• AI model updates and performance improvements
• Force majeure events such as natural disasters or national emergencies
• Distributed denial-of-service attacks, security incidents, telecommunications failures, or failures of infrastructure providers
• Failures, contract termination, policy changes, or API restrictions of Linked Platforms or other third-party providers needed for the Service

2. The Company shall give advance notice within the Service of any planned suspension. If advance notice is impracticable because the event is urgent or outside the Company's control, the Company may give notice afterwards.
3. To the maximum extent permitted by law, the Company is not liable for an interruption caused by an event outside its reasonable control or for maintenance announced in advance.

Article 19 (Discontinuation of the Service)

1. If the Company permanently discontinues the Service, the Company shall give notice within the Service at least 30 days before the discontinuation date.
2. Upon discontinuation, the User is entitled to a refund of fees corresponding to the remaining subscription period, processed through Paddle.

Article 20 (Account Closure and Termination)

1. The User may close the User's account at any time through the settings menu within the Service or through a separate channel provided by the Company. Except for data that must be retained under applicable law or these Terms, the Company shall delete the User's personal data and service data without undue delay in accordance with the Privacy Policy.
2. If a paid subscription remains at the time of account closure, refunds are handled in accordance with Article 17 (Refund Policy).
3. Re-registration with the same email address is possible after closure; however, previous Workspaces, connection settings, and usage data are not restored.
4. The Company may terminate the agreement where the User materially breaches these Terms and fails to cure the breach within a reasonable period after notice, repeatedly fails to pay fees, resells or rents the Service without authorization, or uses the Service for an unlawful purpose. The Company may terminate immediately where urgent action is reasonably necessary to protect Users, the Service, or third parties.

Article 21 (Restriction of Use)

1. If the User violates these Terms or applicable law, the Company may take measures in the following stages. However, the Company may skip stages where the violation is material or immediate action is required.

• Stage 1 — Request for correction and warning
• Stage 2 — Temporary suspension of some features or of the Service (up to 30 days)
• Stage 3 — Termination of the agreement and permanent restriction of use

2. When the Company restricts use, the Company shall notify the User of the reason and the measure by email or within the Service in advance, or afterwards where urgent circumstances make advance notice impracticable.
3. The User may object to a restriction within 14 days of the notice, and the Company shall lift or reduce the measure where reasonable grounds are found.
4. Grounds for restriction include false registration information, non-payment, malware or abnormal traffic, unauthorized copying or reverse engineering, compromised systems, credible third-party rights claims, lawful government requests, circumvention of technical restrictions, and other material violations of these Terms.

Chapter 8. Liability and Disputes

Article 22 (Limitation of Liability)

1. Where the User suffers damage attributable to the Company, the Company's aggregate liability shall not exceed the Service fees paid by the User for the 1 month immediately preceding the event giving rise to the damage, and is limited to ordinary and direct damages.
2. The Company is not liable for special, indirect, or consequential damages, loss of business, or lost profits.
3. Nothing in these Terms excludes or limits any liability that cannot be excluded or limited under applicable law, including liability for death or personal injury caused by negligence, or liability arising from intentional misconduct or gross negligence.
4. Subject to paragraph 3, the Company is not liable for loss caused by the User's unlawful or inaccurate data, insufficient account or system security, use beyond documented limits, failures of the User's devices or software, or use of a free Service.

Article 23 (Disclaimer)

1. The Company makes no warranty as to the accuracy, completeness, or legality of information provided through the Service — including AI-generated information and data retrieved from Linked Platforms — or as to any specific marketing performance.
2. The Company is not liable for Service limitations caused by external factors beyond its control, such as force majeure, failures of Linked Platforms, or policy changes of AI engine providers.
3. The Company is not liable for interruptions in the User's use of the Service caused by reasons attributable to the User.
4. The Company is not liable for legal issues arising from the User's use of Output in advertising without the review required under Article 6.
5. The Service is provided on an "as is" and "as available" basis. To the maximum extent permitted by law, the Company disclaims implied warranties of merchantability, fitness for a particular purpose, non-infringement, uninterrupted availability, error-free operation, and achievement of any particular advertising result.
6. The User represents that it has the rights and lawful basis needed to provide all Input and User Data, and that its content, digital properties, and use of the Service comply with applicable law, advertising standards, privacy requirements, and third-party rights.

Article 24 (Governing Law and Jurisdiction)

1. These Terms are governed by the laws of the Republic of Korea, without prejudice to any mandatory consumer protection provisions of the laws of the User's country of residence.
2. Disputes arising out of the use of the Service shall be subject to the exclusive jurisdiction of the Seoul Central District Court as the court of first instance, except where mandatory law of the User's country of residence grants the User the right to bring or defend proceedings in another forum.

Article 25 (Company Information and Contact)

1. The Company's business information relating to these Terms is as follows.

2. Inquiries, complaints, or suggestions regarding the Service may be submitted by email ([email protected]) or through the customer support menu within the Service. The Company shall respond within 10 business days of receipt.
3. For payment-related inquiries, the User may also contact Paddle directly through the channels set out in the Paddle Checkout Buyer Terms.

Chapter 9. General Terms

Article 26 (Indemnification)

To the extent permitted by law, the User shall defend, indemnify, and hold harmless the Company, its affiliates, officers, employees, agents, service providers, and licensors from third-party claims, losses, liabilities, and reasonable legal costs arising from the User's breach of these Terms or applicable law, infringement of third-party rights, or lack of authority to provide Input or use a client's data. This Article does not apply to the extent a claim was caused by the Company's intentional misconduct or gross negligence.

Article 27 (Notices)

1. The Company may send notices to the email address, telephone number, or in-Service account associated with the User. The User is responsible for keeping contact information current.
2. A notice to all Users may be posted prominently within the Service or on the Company's website for at least 7 days where individual notice is not required by law or these Terms.

Article 28 (Miscellaneous)

1. Matters not addressed by these Terms are governed by applicable law and generally accepted commercial practice.
2. If any provision is held invalid or unenforceable, the remaining provisions remain in full force and the affected provision shall be enforced to the maximum extent permitted by law.
3. A failure or delay by the Company to exercise a right does not waive that right or any later breach.
4. The User may not assign, transfer, sell, rent, or pledge its rights or obligations under these Terms without the Company's prior written consent. The Company may assign these Terms as part of a merger, reorganization, or transfer of the Service, subject to applicable law and required notice.

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Addendum

1. These Terms (v1.2) take effect on October 15, 2026.
2. The previous Terms (v1.1) remain in effect until the day before the effective date of these Terms.
3. The principal changes in this amendment are as follows.

• Article 2: "Usage Data," "Original Service Content," and "Pseudonymized Training Data" added to the definitions
• Article 4: "Report and material generation" added to the description of the Service
• Article 6(1): Prohibitions on model or prompt extraction and on submitting government-issued identifiers or special categories of personal data added
• Article 8(2): The license to Input and Output extended to cover the generation of Pseudonymized Training Data and the training, fine-tuning, and evaluation of AI models developed and operated by the Company
• Article 12(1): Scope of the no-training commitment clarified as applying to public and general-purpose AI models operated by third parties
• Article 12(4): Obligation added for Users acting on behalf of a client to ensure that the processing under paragraph 7 is permitted under their arrangements with that client
• Article 12(5): AI response quality verification, AI security threat detection, and user experience analysis added to the monitoring purposes, with details linked to the Privacy Policy
• Article 12(7) newly added: Use of data for the training and improvement of the Company's own AI models, separation of Original Service Content from Pseudonymized Training Data, pseudonymization method, scope including MCP tool execution, exclusion of Google Workspace API data, deletion, and the right to object
• Article 13(5): Automated AI security filtering and the right to object added