1. Policy Statement & Zero-Tolerance Commitment

1. 1.1 A & C Christofi Ltd (“the Firm”) respects the intellectual property rights of others and expects the same from all users of its digital services.
2. 1.2 The Firm maintain a zero-tolerance policy toward infringement of copyright, trademarks, designs, patents and trade secrets on any Firm-controlled platform.
3. 1.3 Repeat infringers will have their accounts permanently terminated and may be banned by IP address.
4. 1.4 This Policy also aggressively protects the Firm’s own intellectual property, including proprietary methodologies, calculators, templates, training materials and branding.

1.5 DSA & Safe-Harbor Protections

The Firm complies with the EU Digital Services Act (DSA) and the Cyprus transposing legislation. Nothing in this Policy shall be interpreted as requiring general monitoring of user content. The Firm act expeditiously to remove or disable access to infringing material once properly notified, consistent with Articles 6 and 7 DSA.

Signed:
Chris Christofi – Managing Director
Date: 28 November 2025

2. Scope & Covered Platforms

This Policy applies to:

• www.acccyp.com and all sub-domains
• Secure client portal (currently TaxDome)
• Newsletter system, downloadable resources, calculators
• Firm profiles on LinkedIn, YouTube, X (Twitter), GitHub, and any future platforms
• Mobile applications (if launched)
• Any third-party service where the Firm is identified as the content controller

3. Designated Intellectual Property Contact Point

All intellectual property infringement claims, notices, or allegations must be submitted exclusively to the Firm’s designated Intellectual Property Contact Point:

Designated IP Agent
Legal & Compliance Department, A & C Christofi Ltd
Email: legal@acccyp.com (monitored 24/7)
Postal Address: 37 Nicou & Despinas Pattichi Avenue, Evi Court, 3rd Floor, Offices 302–303, CY-3071 Limassol, Cyprus
Telephone: +357 25 332 177

Claims sent elsewhere will not be considered properly notified.

4. Copyright Infringement – Mandatory Notice Requirements

To be acted upon, a copyright notice must contain every element below. While 17 U.S.C. §512(c)(3) (DMCA) format is recognised for clarity, the Firm is primarily bound by EU DSM Directive and Cyprus Copyright law:

1. Physical or electronic signature of the owner or authorised agent
2. Identification of the copyrighted work(s) claimed to be infringed (include registration number if available)
3. Precise location of the infringing material (full URL(s) and screenshot if possible)
4. Your full name, postal address, telephone number and email address
5. Statement that you have a good-faith belief that the use is not authorised
6. Statement that the information is accurate and that you are authorised to act on the behalf of the rights holder
7. Date and place of submission

The Firm may request additional identification documents from claimants to verify the authenticity of a notice, particularly where impersonation or fraudulent claims are suspected. Incomplete notices will be rejected with a request for correction.

Data Protection

Personal data submitted as part of an IP claim or counter-notice is processed solely for the purpose of investigating, documenting, and responding to the claim, in accordance with GDPR, Cyprus Law, and our Privacy Policy.

5. Trademark & Design Infringement Claims

A valid trademark or registered design claim must include:

1. Copy of the trademark/design registration certificate (Cyprus, EUIPO, UKIPO, USPTO or WIPO)
2. Full list of goods/services covered by the mark
3. Exact location of the allegedly infringing use (URL + screenshot)
4. Detailed explanation of why the use is likely to cause confusion or dilution
5. All elements 4–7 from Section 4 above

Unregistered (common-law) trademark claims will only be considered in exceptional circumstances with strong evidence of acquired distinctiveness.

6. Patent & Trade-Secret Claims Procedure

6.1 Patent infringement claims must include:

• Patent number and issuing authority
• Claim chart mapping each asserted claim to the allegedly infringing feature
• Evidence that the patent is valid and enforceable in Cyprus or the EU

6.2 Trade-secret claims must be filed under seal and include:

• Proof that the information derives independent economic value from secrecy
• Evidence of reasonable secrecy measures
• Specific identification of the misappropriated information

The Firm reserve the right to seek a Cyprus court order before removing any material alleged to infringe patents or trade secrets.

6.3 Firm Trade Secrets

The Firm’s proprietary audit programmes, risk-scoring models, workflow engines, templates, and calculators constitute trade secrets under Cyprus law and EU Trade Secrets Directive (2016/943). Any unauthorised use, disclosure, or reproduction is treated as misappropriation and may lead to injunctive relief and damages.

7. Counter-Notice & Put-Back Procedure

7.1 If material has been removed or access restricted following an intellectual property notice, and the affected party believes the removed was in error, the party may submit a counter-notice containing:

1. The counter-notifier’s physical or electronic signature
2. Identification of the removed and restricted material and its original location
3. Statement of good-faith belief that the removal was a mistake
4. Counter-notifier’s full name, address, phone number and consent to the jurisdiction of the Limassol District Court
5. Statement that counter-notifier will accept service of process from the original complainant

7.2 Counter-notices must be emailed to legal@acccyp.com within 10 business days of our removal notice.

7.3 Upon receipt of a valid counter-notice, the Firm will forward it to the original complainant and restore the material in 10–14 business days unless the complainant files court action.

8. Expedited Removal for Clear Infringement

1. 8.1 Where the infringement is manifest and indisputable (e.g., identical copying of protected articles, calculators, templates, or logos), the Firm will remove or disable access within 24 hours of receipt of a complete notice – without waiting for counter-notice.
2. 8.2 The complainant will be informed immediately of the action taken and the content provider notified simultaneously.

9. Repeat Infringer Policy & Termination Matrix

9.1 The Firm maintain a confidential repeat-infringer register reviewed quarterly by the Legal Department.

10. Fair Use / Professional Exception Defence Process

1. 10.1 The Firm recognises legitimate uses such as quotation of laws, IFRS standards, Cyprus Tax Department circulars, and brief excerpts for criticism, commentary or academic purposes.
2. 10.2 Any party whose content is removed may invoke fair use / professional exception by submitting evidence within the counter-notice period.
3. 10.3 All fair-use / professional exception assertions are reviewed by external Cypriot IP counsel before final decision is made regarding reinstatement or continued restriction of the material.

11. Protection of the Firm’s Own Intellectual Property & Anti-Scraping / AI-Training Clause

1. 11.1 All content, calculators, templates, methodologies, audit programmes, training materials and branding are © A & C Christofi Ltd or its licensors.
2. 11.2 Automated scraping, crawling or systematic downloading is strictly prohibited.
3. 11.3 Use of our content (including via automated systems) to train, fine-tune or operate any artificial intelligence, machine-learning model or large-language model is expressly forbidden without prior written licence.

11.3A Database Rights & Anti-Extraction

Systematic extraction or reuse of substantial parts of the Firm’s data, calculators, or knowledge bases (whether manually or via bots/AI tools) is prohibited under the EU Database Directive (96/9/EC) and the laws of The Republic of Cyprus.

11.4 Violation triggers immediate legal action for copyright infringement and breach of database rights.

12. Licensing & Permission Requests

1. 12.1 Third parties wishing to reproduce, adapt or commercially use our materials must submit a formal request to legal@acccyp.com containing:
   • intended use and audience
   • duration and territory
   • proposed credit/attribution
2. 12.2 Decisions are communicated within 15 business days. Standard licences are available for calculators and templates.

13. Reporting Piracy of Our Materials

Clients, partners or members of the public who discover unauthorised use of our copyrighted materials (e.g., pirated templates, fake calculators, rebranded training courses) may report via:

Report IP Theft → piracy@acccyp.com

All good-faith reports are investigated within 48 hours and may qualify for a reward under our Bug-Bounty-style programme.

13A. Compliance with Court Orders

The Firm complies with valid Cyprus, EU, UK, and US court orders, subpoenas, and injunctions relating to intellectual property. Content may be removed or preserved pursuant to such orders without prior notice to the user.

Upon receiving a valid IP claim, counter-notice, or court order, the Firm may place a legal hold on relevant logs, metadata, and backup files. Users agree that the Firm may retain such data until resolution of the dispute.

14. Governing Law, Jurisdiction & Dispute Resolution

1. 14.1 This Policy and all claims are governed exclusively by the laws of the Republic of Cyprus.
2. 14.2 The courts of Limassol shall have exclusive jurisdiction.
3. 14.3 Before commencing litigation, parties agree to attempt mediation through the Cyprus Chamber of Commerce & Industry (maximum 30 days).
4. 14.4 The Firm reserves the right to seek injunctive relief without notice in any jurisdiction to protect the Firm’s intellectual property.

15. Policy Version Control, Updates & Contact

1. 15.1 Current version: 2.0 – Effective 1 December 2025
2. 15.2 Material changes will be notified by banner on the website and direct email to registered users.
3. 15.3 Previous versions are archived and available on request.
4. 15.4 Intellectual Property Notices & Inquiries:
   Legal & Intellectual Property Department
   Email: legal@acccyp.com
   Telephone: +357 25 332 177
   Address: 37 Nicou & Despinas Pattichi Avenue, Evi Court, 3rd Floor, Offices 302–303, CY-3071 Limassol, Cyprus
5. 15.5 Non-Waiver: Failure to enforce any provision of this Policy does not constitute a waiver of that provision or any other rights.

END OF POLICY