Advertising Policy

This document is provided in English and Georgian. In case of discrepancy, the English version shall prevail.

Document

Advertising Policy

Version

1.1

Effective Date

15 October 2026

Last Updated

15 October 2026

Operated by

Nixyum LLC · Reg. No. 400458045

Registered Address

Tbilisi, 13 Nikoloz Janashia Street, Georgia

Governing Law

Georgia

Advertising enquiries

[email protected]

011. Introduction and Purpose

This Advertising Policy governs all paid advertising on the Nixyum platform, including promoted posts, display placements, and any other commercial advertising formats made available by Nixyum. It applies to all Advertisers — whether individuals, businesses, or agencies — and to all advertising content submitted, purchased, or displayed on the Platform.

This Policy is designed to ensure that advertising on the Platform is lawful, truthful, non-discriminatory, and consistent with the rights and expectations of the Platform's Users. It operates alongside and subject to the Terms of Service, Community Guidelines, and the Privacy Policy, all of which are incorporated by reference. Capitalised terms used in this Policy have the meanings assigned in the Master Definitions.

Compliance with this Policy does not guarantee that an advertisement will be approved. Nixyum reserves the right to reject, remove, or restrict any advertisement at its sole discretion where it determines that the advertisement is inconsistent with the Platform's standards, values, or legal obligations, regardless of whether the advertisement falls within a technically permitted category.

022. Advertising Is Not Offered Yet

Nixyum does not show advertising at present. There are no paid placements or promoted posts, no advertising cookies and no ad targeting, and no Personal Data is used for advertising or shared with Advertisers. This Policy sets out the rules that advertising will follow if Nixyum introduces it. Before any advertising starts, Nixyum will update this Policy to describe how its advertising actually works and will tell Users at least thirty (30) days in advance, through the Platform or by email.

Businesses interested in advertising on the Platform once it is offered may write to [email protected].

033. Advertiser Eligibility

To advertise on the Platform, an Advertiser must:

• Hold a valid Nixyum Account in good standing.
• Be a natural person aged 18 or over, or a duly registered legal entity with authority to enter into binding commercial agreements.
• Accept and comply with this Advertising Policy, the Terms of Service, and all Policies incorporated by reference.
• Hold all licences, registrations, and authorisations required by Georgian law and the law of any other jurisdiction in which the advertisement is targeted.
• Not be subject to a current advertising suspension or permanent ban issued by Nixyum.

Nixyum reserves the right to require identity verification, business registration documentation, or regulatory licence evidence from any Advertiser before approving or continuing to publish advertisements.

044. General Requirements for All Advertisements

4.1 Truthfulness and Non-Deception

All advertisements must be truthful, accurate, and not misleading. Specifically:

• All factual claims must be substantiated by reliable evidence. Health, financial, scientific, or performance claims that cannot be substantiated are prohibited.
• Advertisements must accurately represent the product, service, brand, or offering being promoted. The advertisement content must correspond to the linked landing page or destination.
• All material terms, conditions, limitations, and exclusions applicable to an advertised offer (including time limits, eligibility requirements, and price conditions) must be clearly stated or referenced within the advertisement.
• Bait-and-switch tactics — advertising one product or price and directing the User to a different, typically inferior, offering — are prohibited.
• Advertisements must not use sensationalist, misleading, or disproportionate imagery or headlines to generate clicks or impressions.

4.2 Legal Compliance

All advertisements must comply with:

• The Law of Georgia on Advertising and all applicable Georgian secondary legislation.
• All sector-specific Georgian laws applicable to the advertised product or service (including Georgian financial services regulation, pharmaceutical regulation, and telecommunications law).
• Consumer protection legislation applicable in the jurisdiction(s) targeted by the advertisement.
• The Nixyum Terms of Service and all Policies.

The Advertiser bears sole responsibility for ensuring that their advertisement complies with all applicable laws. Nixyum's review and approval of an advertisement does not constitute a representation that the advertisement is legally compliant, and does not limit the Advertiser's liability for non-compliance.

4.3 Non-Discrimination

Advertisements must not discriminate against, degrade, or incite discrimination against individuals or groups on the basis of any protected characteristic, including race, ethnicity, national origin, religion, gender, age, disability, sexual orientation, or gender identity. Targeting tools, where available, must not be used to unlawfully exclude protected groups from accessing lawful products and services.

4.4 Intellectual Property

Advertisers must hold all rights, licences, and permissions required to use every element of their advertisement, including images, video, audio, fonts, logos, and text. Advertisements must not:

• Reproduce or imitate the branding, trade dress, or intellectual property of a third party without authorisation.
• Use the name, likeness, voice, or image of any person without their express consent.
• Imply an endorsement by a person or organisation without verifiable authorisation.
• Reproduce copyrighted material without a valid licence.

Intellectual property infringement notices in respect of advertisements are processed in accordance with the Content Moderation & Takedown Policy, Sections 8 and 9. Upon receipt of a valid notice, Nixyum will remove the relevant advertisement and notify the Advertiser, who may submit a counter-notice in accordance with that procedure. The Advertiser assumes full liability for any infringement claim arising from their advertisement.

4.5 Ad Identification and Disclosure

All paid advertisements must be clearly identified as such. Once advertising is offered, Nixyum will apply a "Sponsored" label to every paid placement. In addition:

• The content of an advertisement must not be designed to appear as organic User Content, a system notification, a news report, or any other non-commercial communication.
• Fake UI elements — including fake close buttons, fake progress bars, fake system alerts, or fake prize notifications — are prohibited.
• Sponsored and influencer content must be disclosed in accordance with the "Influencer marketing and sponsored content" row of Section 6 of this Policy.

4.6 Technical and Quality Standards

All advertisements must:

• Comply with Nixyum's published technical specifications for the relevant ad format (dimensions, file size, aspect ratio, character limits, video duration). Non-compliant creative materials will be rejected.
• Be of sufficient technical and visual quality to maintain the User experience of the Platform. Blurred, pixelated, or illegible creative materials will be rejected.
• Not contain audio that auto-plays without User initiation.
• Not contain rapidly flashing or strobing visual elements that may cause discomfort or risk of photosensitive seizure.
• Not initiate automatic downloads on the User's device.
• Not employ excessive redirect chains. The User must be taken directly to the stated destination in no more than two redirects.

055. Prohibited Content

The following categories of advertisement are absolutely prohibited on the Platform regardless of the jurisdiction in which they are displayed. These prohibitions are not subject to exception, waiver, or prior written approval.

066. Restricted Content — Conditional Permissions

The following categories of advertisement may be permitted subject to the conditions set out in the table below. An advertisement in a restricted category that does not satisfy all applicable conditions will be treated as prohibited and will be rejected or removed. Nixyum reserves the right to suspend any restricted category at any time where adequate compliance cannot be technically or operationally ensured.

077. Targeting Rules

7.1 General Targeting Principles

Where Nixyum makes audience targeting tools available to Advertisers, the following rules apply to all targeting activities:

• Targeting must be used to reach a relevant, lawful audience — not to exclude protected groups from access to lawful products or services.
• Targeting parameters must not be based on Special Category Data (as defined in the Master Definitions), including health status, political opinions, religious beliefs, racial or ethnic origin, sexual orientation, or trade union membership.
• Advertisers must not attempt to construct proxy targeting categories that functionally achieve targeting on the basis of Special Category Data (e.g., using location data to target a specific ethnic community).
• Targeting never combines what a User does as Nex with what they do as Nyx, and never reveals to an Advertiser that a Nex and a Nyx belong to the same person (Privacy Policy §6 and §15.2).

7.2 Minor Protection — Absolute Prohibition

The Platform is restricted to adults aged 18 and over. The following targeting and exposure restrictions apply to protect against the exposure of any User who is in fact a Minor (under 18) notwithstanding the Platform's age restriction, and are non-negotiable:

• No advertisement for alcohol, tobacco, gambling, adult content, or dating services shall be targeted at or displayed to a User identified as a Minor.
• The Personal Data of any User identified as a Minor (under 18) shall not be used for the purposes of behavioural advertising targeting under any circumstances, and such a User's Account is blocked and, unless a review finds a mistake, deleted, as the Data Retention & Deletion Policy §7.3 describes.
• Where Nixyum determines that adequate technical exclusion of Minor Users from a restricted category advertisement cannot be ensured, Nixyum will suspend that advertisement category entirely rather than risk exposure of Minor Users.

7.3 Privacy Compliance in Targeting

Direct Marketing — Opt-In Consent Only. Direct Marketing communications (as defined in the Master Definitions) sent by Nixyum or on Nixyum's behalf to a Data Subject are conducted exclusively on the basis of the Data Subject's freely given, specific, informed, unambiguous, and prior opt-in consent, in accordance with the Georgian Data Protection Law. Consent is not implied from registration, Account creation, Platform use, or purchase. Direct Marketing consent is recorded by Nixyum with timestamp and applicable Policy version. The Data Subject may withdraw consent at any time by using the unsubscribe mechanism in any marketing communication or by contacting [email protected]; Nixyum shall cease all Direct Marketing communications within seven (7) working days of receipt of the withdrawal. The Personal Data of any User identified as a Minor (under 18) shall not be used for Direct Marketing under any circumstances.

Where ad targeting involves the processing of User Personal Data:

• All such processing is subject to the Privacy Policy, the Data Map, and the Georgian Data Protection Law.
• Behavioural targeting will take place only with the User's consent, asked for that purpose when advertising is introduced. Consent to Analytics cookies is never treated as consent to advertising.
• Users who have not given that consent are not subjected to behavioural targeting. Contextual advertising (not based on personal identifiers) may still be shown to them.
• Where ad targeting constitutes Direct Marketing within the meaning of the Master Definitions, Users may withdraw consent or otherwise opt out at any time, and Nixyum shall cease such processing within seven (7) working days of receipt of the opt-out request, in accordance with the Privacy Policy and the Georgian Data Protection Law.
• Advertisers shall not upload User personal data (including customer lists or email addresses) to the Platform's targeting systems without prior written approval from Nixyum confirming the lawful basis for such processing.

088. Landing Page Requirements

The destination to which an advertisement directs the User must satisfy the following requirements:

• The landing page must be fully functional, accessible, and consistent with the advertisement content. Bait-and-switch destinations are prohibited.
• The landing page must not contain content that would be prohibited on the Platform under this Policy or the Community Guidelines.
• Where the landing page collects Personal Data or deploys cookies, it must operate a compliant privacy notice and consent mechanism in accordance with applicable data protection law.
• The landing page must not initiate automatic downloads, require immediate form submission without prior context, or employ deceptive UI patterns.
• Advertisers must not alter the landing page after advertisement approval in a manner that would cause the advertisement to fall out of compliance with this Policy. Post-approval page changes that affect compliance will result in immediate advertisement removal.
• Nixyum reserves the right to conduct landing page reviews at any time during an active campaign.

099. Review, Approval, and Monitoring

9.1 Pre-Publication Review

All advertisements are subject to pre-publication review by Nixyum before being displayed on the Platform. Nixyum will complete initial review within forty-eight (48) business hours of submission. The Advertiser will be notified of approval or rejection through the Platform's advertising dashboard or by email.

Rejection notifications will specify the general basis for rejection (e.g., content category, missing disclosure, technical non-compliance). The Advertiser may correct the identified issue and resubmit. Nixyum's review and approval of an advertisement does not represent a guarantee of continued publication or a waiver of the right to remove the advertisement post-publication.

9.2 Post-Publication Monitoring

Nixyum monitors active advertisements on an ongoing basis. Advertisements may be suspended or removed post-publication where:

• A User submits a Report identifying a potential Policy violation. All ad Reports are reviewed within twenty-four (24) hours of receipt.
• Nixyum's automated monitoring systems detect prohibited content or malicious code in the advertisement or its landing page.
• Nixyum becomes aware of a change in law, regulatory guidance, or Platform policy that affects the permissibility of the advertisement.
• The Advertiser has altered the landing page in a manner affecting Policy compliance.
• A valid intellectual property infringement notice is received in respect of the advertisement's content.

9.3 User Reporting of Advertisements

Users may report advertisements they believe violate this Policy through the in-app "Report Ad" function. Nixyum will review all ad Reports and take action where a violation is identified. Users may also suppress specific advertisements from their feed through the in-app "Hide Ad" function. Suppression does not remove the advertisement from the Platform but removes it from the requesting User's feed.

1010. Enforcement

10.1 Ad Removal

Where an advertisement is found to violate this Policy, it will be removed from the Platform immediately. Where removal occurs post-publication, the Advertiser will be notified of the reason. No refund or credit will be issued for advertising spend attributable to a period during which a Policy-violating advertisement was live, except at Nixyum's sole discretion or as required by applicable law.

10.2 Advertiser Warning and Suspension

The following escalating measures apply to Advertiser violations:

• First violation (minor): Written warning issued. Advertiser may correct and resubmit.
• Repeated minor violations or single serious violation: Temporary advertising suspension. Duration is proportionate to the nature of the violation and determined at Nixyum's discretion.
• Persistent non-compliance or fraudulent conduct: Permanent advertising ban. Advertiser's Account may also be subject to Enforcement Action under the Terms of Service.
• Criminal content (CSAM, malware, fraud, threats of violence): Immediate permanent ban, and a report to the competent authorities where the law requires one. CSAM is also reported to NCMEC, as the Content Moderation & Takedown Policy §12.2 describes.
• Right of appeal: Advertisers subject to suspension or permanent ban may appeal as described in the Content Moderation & Takedown Policy §11.2. There is no appeal against Content a person has confirmed as CSAM, terrorism-related content, or actions taken pursuant to a valid court order or law enforcement direction.

10.3 Nixyum's Absolute Right of Refusal

Nixyum reserves the right to refuse, suspend, or terminate advertising services to any Advertiser at any time, at its sole discretion, including where the Advertiser's products, services, or conduct are inconsistent with the Platform's values or could harm the Platform's Users or reputation, regardless of whether a specific Policy provision has been violated.

1111. Advertiser Data Protection Obligations

Where an Advertiser receives any User data through the Platform — whether through lead generation forms, aggregated campaign performance reports, or any other mechanism — the Advertiser:

• Shall process such data solely for the purpose for which it was collected and disclosed, as agreed with Nixyum.
• Shall comply with all applicable data protection law, including the Georgian Data Protection Law, in relation to any User Personal Data received.
• Shall not use User data received through the Platform to build independent advertising profiles, conduct re-targeting outside the Platform, or sell or transfer data to third parties without Nixyum's prior written approval and the User's informed consent.
• Shall implement appropriate technical and organisational measures to protect User data against unauthorised access, loss, or disclosure.
• Shall notify Nixyum promptly — and in any event within twenty-four (24) hours — if the Advertiser becomes aware of any unauthorised access to or disclosure of User Personal Data received through the Platform.

Nixyum provides only aggregated, anonymised campaign performance metrics to Advertisers by default. Individual User data is not provided to Advertisers except where the User has provided explicit, informed consent through Platform mechanisms operated in accordance with the Privacy Policy and the Georgian Data Protection Law.

1212. Advertiser Liability and Indemnification

The Advertiser is solely responsible for all content submitted for publication on the Platform and for ensuring that such content complies with this Policy, the Terms of Service, and all applicable laws.

The Advertiser shall indemnify, defend, and hold harmless Nixyum LLC and its officers, directors, employees, agents, and successors from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or relating to: (a) any advertisement submitted or published by the Advertiser; (b) the Advertiser's breach of this Policy or the Terms of Service; (c) any infringement of a third party's intellectual property rights by the Advertiser's advertisement; (d) any false, misleading, or unlawful claim made in the Advertiser's advertisement; or (e) the Advertiser's violation of applicable law.

Nixyum's liability to the Advertiser in connection with advertising services is limited to the aggregate amount of advertising fees paid by the Advertiser in the thirty (30) days preceding the event giving rise to the claim. Nixyum is not liable for any indirect, consequential, incidental, or punitive damages.

1313. Changes to This Policy

Nixyum may update this Advertising Policy to reflect changes in law, regulatory guidance, Platform capabilities, or operational practice. Active Advertisers will be notified of material changes at least thirty (30) days before the change takes effect, via the Platform's advertising dashboard or by email, except where a shorter period is required by law or is necessary for reasons of security or regulatory compliance. Where a policy change renders a previously approved advertisement non-compliant, Nixyum will provide notice of the change and a reasonable period for the Advertiser to modify or withdraw the affected advertisement before it is removed.

Continued use of the Platform's advertising services after the effective date of any update constitutes acceptance of the revised Policy.

1414. Contact

Advertising Enquiries

[email protected]

Legal & Compliance

[email protected]

Ad Reports (Users)

[email protected]

Privacy & Data Protection

[email protected]

Data Controller

Nixyum LLC · Tbilisi, 13 Nikoloz Janashia Street, Georgia · Reg. No. 400458045

Supervisory Authority

State Audit Office of Georgia (SAO) · pdp.sao.ge

© 2026 Nixyum LLC. All rights reserved.