Rules of the Public Interest Press Releases programme

This is a translation of the Romanian text, provided for convenience. In case of any difference of meaning, the Romanian version prevails, as the language in which the agreement is concluded.

In short

- Verified organisations (NGOs, schools, universities, public hospitals and city halls) publish their public-interest press releases free of charge: up to 8 publications a month, at most 2 outlets per press release, on 19 outlets of our own network. What you do not use in a month does not carry over. - We ask for nothing in return. Below each press release we add a line saying who sent it and that it was published free of charge through the programme. - Every press release is read by a person before publication. Through the programme we do not publish political advertising, commercial content or announcements of funded projects; with each press release you declare that it is not political advertising. - Children may appear only with their parents' written consent, which you email to us before approval. Health data appear only with the person's written consent. We keep no copies of these documents. - Texts of programme organisations do not go through artificial intelligence services. - We explain every decision to you in writing. You can ask for it to be reviewed within 6 months, from Support, and a person answers you. - You can withdraw at any time. We announce changes to these rules at least 30 days in advance. - How we use personal data in the programme is set out in Annex 1, at the end of these rules.

This summary helps you find your way; the full text below is what applies.

1. Who offers the programme

The "Public Interest Press Releases" programme ("Comunicate de interes public") is offered by ARC MEDIASOFT SRL, the company that operates the Comunicate.eu platform:

- registered office: Aleea Botorani nr. 6, bl. V83, sc. 3, et. 5, ap. 79, sector 5, Bucharest, Romania; - Trade Register number: J40/13626/2013; - tax registration code: RO32431001; - email: contact@comunicate.eu; phone: +40 721 936 907.

In these rules, "we" means ARC MEDIASOFT SRL. "The organisation" is the one that joins the programme. "You" means the organisation, acting through the people who use its Comunicate.eu account.

The address contact@comunicate.eu is our single point of contact for programme organisations and for authorities, including within the meaning of articles 11 and 12 of Regulation (EU) 2022/2065 on digital services. You may write to us in Romanian or in English.

2. What the programme is

The programme is a promotional initiative of Comunicate.eu. Through it we publish, free of charge, on the outlets of the Comunicate.eu own network, the press releases of verified organisations: NGOs, schools, universities, public hospitals and city halls. The programme's 19 outlets are operated by us.

We ask for nothing in return: no payment, link, logo, review, mention or exclusivity. The only sign of the programme is the line we add below each press release (section 12).

We run the programme because our outlets need public-interest news and because the programme makes the platform known. That interest is ours and creates no obligation for you.

3. What kind of agreement this is

When we approve your application, a participation agreement is concluded between the organisation and us, on the terms of these rules. The organisation pays nothing and owes us nothing in return. We undertake to read the press releases you send, to publish the approved ones within the limits below, and to explain our decisions to you.

No specific law governs this agreement, so the general rules of the Romanian Civil Code on contracts apply to it (art. 1168).

The programme:

- is not a sponsorship within the meaning of Law no. 32/1994: we do not transfer money or goods to you, we do not conclude a sponsorship contract, and we do not ask you to promote our name or brand; - is not a donation: we give you no goods and transfer no right to you; - does not create a partnership, an association or an agency relationship between us. You do not speak on our behalf, and we do not speak on yours.

The agreement is for an indefinite period and ends as set out in section 20.

4. Who can join

The programme is open to active organisations in Romania that have their own tax identification number:

- associations, foundations and federations (non-governmental organisations); - state, private or denominational pre-university education units, accredited or provisionally authorised to operate, with their own legal personality, that are not companies: kindergartens, schools, high schools, colleges, seminaries, children's palaces and clubs; - accredited state, private or denominational higher education institutions and education providers provisionally authorised to operate: universities, academies, institutes, schools of higher education; - public hospitals, including the institutes, sanatoriums and preventoriums of the public health system; - city and town halls: communes, towns, municipalities and the sectors of Bucharest, enrolled with their own tax number.

The law organises private and denominational education on a non-profit basis and gives private and denominational education units legal personality from the date of their provisional operating authorisation (art. 27(1) and (3) of Law no. 198/2023 on pre-university education). Higher education institutions may be state, private or denominational, have legal personality and a non-profit character; private ones are legal persons governed by private law and of public utility (art. 7(4) and (6) of Law no. 199/2023 on higher education). A private or denominational school or university that appears at ANAF as an association or foundation falls into the category of schools or universities, respectively, not of NGOs.

Other public institutions cannot join for the time being.

The following cannot join:

- companies, including state-owned ones and those that set up or run an education unit (the education unit may join in its own right if it meets the conditions above); - individuals, authorised self-employed persons and sole or family enterprises; - political parties, political and electoral alliances, their structures and the organisations linked to them: youth, women's and senior organisations, and the parties' foundations, institutes and political schools; - organisations of citizens belonging to national minorities that take part in elections; - initiative committees, referendum committees and any organisation set up to influence the outcome of an election or a referendum; - candidates and elected officials, in a personal capacity; - trade unions and employers' organisations; - religious denominations and their religious units, such as parishes and monasteries (denominational schools and universities may join as education units, under the conditions above); - homeowners' associations; - counties, county councils and prefectures.

A tax identification number can be enrolled in only one account at any given time. The application is sent by the owner or an administrator of the organisation's account.

5. Public institutions and city halls

Participation involves no payment for publications, so it is not a public procurement, which is for consideration (art. 3(1)(l) of Law no. 98/2016). The institution receives no money or goods, so it has no donation or sponsorship to accept. The only possible monetary obligation is the one in section 14: reimbursing compensation we were ordered to pay, by a final judgment or under a settlement the institution agreed to, because of a press release it sent in breach of its guarantees.

The rules are accepted by the head of the institution (for city halls, the mayor) or by a person authorised by them. Whoever accepts declares that they have this right and that participation complies with the institution's internal rules on public communication.

The terms are the same for all institutions. The programme has no connection with any procurement, authorisation or funding procedure of the institution and gives no one an advantage in such procedures. The institution benefits from it, not any particular person. Through the programme we offer no personal advantage to the institution's employees or elected officials.

The institution's press releases are public information about its activity. They follow the rules in section 11, which are stricter during election periods.

6. How to apply and when the agreement is concluded

The steps:

1. You sign in to the organisation's Comunicate.eu account or create one. 2. You open the Programme page and fill in the application: the type of organisation, the tax number, the website if the organisation has one, an official email address and, if you like, a note. Next to the email address fields you will find the link to Annex 1, which explains how we use these data. 3. You read these rules and accept them with the first tick box in the form. With the second, separate tick box you expressly accept the clauses listed in section 23. 4. You send the application. Until then you can correct any field in the form. After sending, write to us from Support or at contact@comunicate.eu and we correct the data. 5. You confirm that you represent the organisation, as set out in section 7. 6. A person on our team decides. You receive the decision by email and see it on the Programme page.

When the agreement is concluded. The application you send is the organisation's offer to take part on the terms of these rules. The agreement is concluded when we notify you of the approval. Until then you can withdraw the application from the Programme page.

Confirmation. Immediately after you send the application, the Programme page shows that we received it, the version of these rules you accepted and the date it was sent. At the same time we send a confirmation email to the address of the account that sent the application, with the version of the rules accepted, the date and time of sending, the fact that you separately accepted the clauses in section 23, and the link to the rules.

Where to find the agreement. For each of the two tick boxes we keep the version accepted, the account and the person who ticked it, the date and time, the IP address and the browser type. On the Programme page you can always see which version you accepted. The rules in force are public on the website, where you can save or print them. We send you any earlier version on request.

Language. The agreement is concluded in Romanian. The English version is a translation. In case of any difference, the Romanian text prevails.

Codes of conduct. We have not subscribed to any codes of conduct that apply to the programme.

Who accepts. The person who sends the application declares that:

- they have the right to bind the organisation, as its legal representative or with the representative's authorisation; - the data in the application are true; - participation complies with the organisation's founding documents and internal rules.

Acceptance is given electronically, from the organisation's account. Sending press releases after approval confirms the acceptance.

7. How we verify the organisation

1. The tax number. We look it up at ANAF, the Romanian tax authority, in the taxpayer register and in the Register of entities/religious units for which tax deductions are granted. The number must exist, and the organisation must not be deregistered, tax-inactive or, according to ANAF data, in dissolution, liquidation, bankruptcy, insolvency, reorganisation or with its activity suspended. 2. The kind of organisation. A person on our team confirms the category: for NGOs, from the ANAF data and the National NGO Register; for public institutions, from the Ministry of Finance list of public entities or from the official website. For private and denominational schools we confirm the accreditation or provisional operating authorisation in the records published by the Romanian Agency for Quality Assurance and Inspection in Pre-University Education (ARACIIP), and for private and denominational universities in the records of the Romanian Agency for Quality Assurance in Higher Education (ARACIS) and in the accreditation act published in the Official Gazette of Romania. 3. Representation. We make sure the application really comes from the organisation: - if the official address is on a .gov.ro or .edu.ro domain, or on the domain of the organisation's website, we send a confirmation link there, valid for 7 days; if too many links have already been sent to the same organisation or address in the last 7 days, confirmation is done with a code, as below; - otherwise, we send a 6-digit code to an official address we found ourselves, which you enter on the Programme page; the code is valid for 7 days and allows at most 5 attempts; - instead of the link or the code, we can accept a letter signed by the legal representative, which you email to us at contact@comunicate.eu; for institutions, with a registration number. What happens to the letter is set out in section 15, under "Documents you send us".

We never ask for copies of identity documents and we never call the phone numbers given in the application. Do not send us identity documents or personal numeric codes; if they appear in the letter, we do not record them anywhere. 4. The decision. A person on our team makes it, usually within one working day of the representation being confirmed. If we reject the application, we tell you why (section 13).

What is automatic at enrolment. The form does not accept the application if ANAF does not find the tax number, or shows that it belongs to a company, an authorised self-employed person or a sole or family enterprise, that the organisation is deregistered, tax-inactive or, according to ANAF data, in dissolution, liquidation, bankruptcy, insolvency, reorganisation or with its activity suspended, that it falls into a category that cannot join, or that its type cannot be established. We show you the reason at once. If the ANAF data or our classification is wrong, write to us from Support: a person repeats the check and answers you.

Rechecks. Once a month we check the tax number at ANAF again. If ANAF no longer finds the tax number or shows the organisation as deregistered, tax-inactive, in dissolution, liquidation, bankruptcy, insolvency, reorganisation, with its activity suspended or ineligible, the monthly top-up of publications stops until a person decides. Once a year we reconfirm that the person using the account still represents the organisation: if the representation was confirmed with a link on the organisation's domain, we send a new link to the same address; otherwise, our team sends a code to the organisation's official address or accepts a new letter. If the legal representative, the official address or the website changes, let us know.

8. What you get

- Up to 8 publications a month. A publication means one press release appearing on one outlet. For example: 4 press releases on 2 outlets each. - At most 2 outlets for each press release. The same text, sent from another article within the following 12 months, is still the same press release: together, the two submissions appear through the programme on at most 2 outlets. The rule is checked when you send the press release and again at approval, on the text as it stands then. - 19 outlets from our own network, chosen by us for their news, civil society, local news and health profile. The list is shown in the app when you publish, and on the programme page. - A monthly report as a PDF, with what was published and the article links, ready to show to funders.

Publications are topped up to 8 at the start of each calendar month, Romanian time. After approval you receive the publications for the current month. Whatever you do not use in a month does not carry over to the next one. A publication counts in the month you placed the order. A rejected or cancelled one does not count, and its slot is freed.

Each outlet takes at most 20 programme press releases a month, so that it keeps its profile. If an outlet has reached its limit, you choose another.

If an outlet leaves the network, we may replace it with one of a similar profile. Any other change to the list is made as a change to these rules (section 21).

Above these limits, or on other outlets, you can publish at any time as paid content, at the catalogue price.

9. Which press releases the programme covers

Programme press releases are of public interest and come from a clearly identified sender: the organisation's activity, community services, events, information, prevention and volunteering campaigns, results, humanitarian appeals and fundraising into the organisation's official account.

Press releases are published in Romanian.

10. What we do not publish through the programme

The following are excluded all year round:

- political advertising and the other press releases excluded in section 11; - commercial content: products, prices, offers, promotion of sponsors, companies' corporate social responsibility activities; - promotion of services or products that the organisation offers for a fee, such as tuition fees, courses, paid medical consultations or tests, or tickets, with prices, offers or calls to buy. An announcement of an admission round, of a free service or of an event with free entry remains in the programme; - announcements of projects funded by EU funds or the national recovery plan (PNRR), tenders and job advertisements; - fundraising into personal accounts; - the personal data excluded in section 15, and data about children published without the consent required there; - accusations against individuals; - gambling, cryptocurrencies and adult content; - any illegal or misleading content, or content that infringes the rights of others.

Commercial content, project announcements, tenders and job advertisements can be published as paid content, at the usual price.

A press release contains at most 3 links to other websites.

11. Political advertising, elections and referendums

What we do not publish, all year round. Through the programme we do not publish political advertising within the meaning of Article 3, point (2), of Regulation (EU) 2024/900 on the transparency and targeting of political advertising, even though publication is free. As a precaution, we also refuse press releases that may not be political advertising within the meaning of that Regulation but carry a political charge. Specifically, we refuse press releases:

1. sent by a political actor, for them or on their behalf: a party or political alliance, a candidate, a person holding an elected office (for example the President of Romania, a member of the Romanian or European Parliament, a mayor, deputy mayor, local or county councillor, county council president), a member of the Government or a party leader. Official communication by a public institution does not fall here, under the conditions below; 2. that promote or criticise a party, a candidate or an elected person, including through that person's records of achievement, thanks, congratulations or promises; 3. that concern elections or referendums (European, national, local, partial or internal party elections): calls to vote, not to vote or to vote in a certain way, and the presentation, assessment or comparison of candidates or voting options; 4. that seek to influence the initiation, drafting, adoption, amendment, repeal or rejection of a normative act (a law, an emergency or simple government ordinance, a government decision, an order, a local or county council decision, an act of the European Union): support for or opposition to a draft, appeals to members of parliament, councillors or other decision-makers, petitions, citizens' initiatives and the collection of signatures for them, and calls to send proposals in a particular direction in a public consultation. This rule concerns only normative acts, which apply to an indeterminate number of people. It does not concern individual decisions, such as the allocation of a plot of land, a permit, the approval of a specific project or an appointment; 5. labelled "material publicitar politic" (political advertisement) or bearing an identification code assigned by the Permanent Electoral Authority.

What we can publish, if it complies with the rest of these rules:

- information, prevention and awareness campaigns, fundraising for social, humanitarian or medical causes, and the organisation's events, services and results, even when the topic is also debated in politics, as long as the press release does not ask for a normative act to be adopted, amended or rejected and does not refer to a vote; - an explanation of a law or decision already adopted and of its effects; - official information from city halls and the other public institutions in the programme: decisions adopted, services, opening hours, works, warnings, the announcement of a public consultation and of how to take part. An institution's press release may quote an elected official only in their official capacity and only as far as needed for the information conveyed. We do not publish press releases whose subject is the elected person.

The election period. For the programme, the election period starts on the earliest of these dates:

- 30 days before polling day; - the start of the election campaign set by law; - for a referendum, the day its date was publicly announced.

It ends the day after the vote, at 12:00 Romanian time. Where there is a second round, it ends the day after the second round, at the same time.

The election period applies:

- to organisations throughout the country, for presidential, parliamentary, European Parliament and general local elections and for a national referendum; - for partial local elections and local referendums, to organisations whose registered office is in the commune, town, municipality or Bucharest sector where the vote takes place. Where the vote is for the president of the county council or for the general mayor of Bucharest, to organisations in the whole county or the whole of Bucharest, respectively.

We take the registered office from the ANAF data. We set the periods from the acts published in the Official Gazette of Romania and from the announcements of the Permanent Electoral Authority. On request, we tell you whether an election period concerns you.

During the election period, for organisations in the area where the vote takes place:

1. No press release names, quotes or shows in images candidates, parties or alliances. An elected official standing in that election is treated as a candidate. Press releases contain no party or campaign logos, colours or slogans and no links to their pages. 2. The public institutions in the programme (city halls, state schools and universities, public hospitals) publish only public service information: the institution's opening hours and services, interruptions and works, safety and public health warnings, enrolments, exams, scholarships and competitions, cultural, sports and educational events, public consultations required by law and, for city halls, information on how the vote is organised (polling stations, hours, documents needed), without calls to vote. Their press releases do not name, quote or show in images elected officials (for example the President of Romania, members of the Romanian or European Parliament, mayors, deputy mayors, local and county councillors, county council presidents and vice-presidents) or members of the Government. The office may appear, without a name, only where an official act requires it, for example "by mayoral order no. …". 3. Public institutions do not publish records of achievement of the institution or its leadership, inaugurations, launches, promised projects, or distributions of goods or aid presented as achievements. Practical information about a new service (since when it runs, where and how to use it) remains allowed. 4. Other organisations may name an elected official only in their official capacity and only as far as needed for the information conveyed, without praise and without criticism. The all-year ban on praising or criticising elected officials (point 2 at the start of this section) still applies. 5. From 7:00 on the Saturday before polling day until the end of the election period we publish only urgent announcements (safety, health, service interruptions) and city halls' information on how the vote is organised. Press releases published earlier stay online.

Regardless of the area, we do not publish press releases that name candidates in an ongoing election or that concern the subject of an ongoing referendum.

Your declaration. With each press release sent through the programme you tick, on behalf of the organisation, the declaration that the press release is not political advertising and complies with this section. Without the tick, the press release cannot be sent through the programme. The tick stands as the organisation's declaration, required by Article 7(1) of Regulation (EU) 2024/900, that the publication requested does not constitute a political advertising service within the meaning of Article 3, point (5), of that Regulation. We keep the tick, the date and the IP address from which it was sent. You are responsible for the accuracy of the declaration.

How we decide. The person on our team who reads the press release takes into account its content, who sends it, its language, its context and timing, the means by which it is disseminated, its audience and its purpose (Article 8(1) of Regulation (EU) 2024/900), as well as the European Commission Guidelines C/2025/5514. When in doubt, we reject the press release and tell you why. You can resubmit it after the election period. A rejected press release does not count against the month's publications.

Why. Law no. 334/2006 requires campaign expenses to come only from contributions of candidates or political parties and propaganda materials to be paid for exclusively by their beneficiaries (art. 28(1)(a) and art. 36(4)), and prohibits associations and foundations from financing an electoral competitor's campaign in any way (art. 33(2)). An election material published free of charge would breach these rules. We do not carry out activities financed from public funds, so the ban in art. 33(1) on companies carrying out such activities does not concern us directly; we still refuse any election material, for the reasons above. Public institutions may not use their resources to support the activity or campaign of a party or an independent candidate (art. 14(1) and (5) of the same law).

12. How publishing works

- Programme press releases are sent only from the app. Orders placed through the API, through artificial intelligence assistants connected to the account or through email import do not use the programme. - The form does not accept a programme press release with more than 3 links to other websites. A web address written on its own in a paragraph is also published as a link and counts towards this limit. - With each press release you tick the declaration in section 11. - Every press release is read by a person before publication. We usually answer within one working day. - If you change the text after approval, the press release goes back for approval. - The programme does not include writing the text, extra services or scheduling publication for a specific date. - An approved press release usually goes live within the turnaround shown next to each outlet, in a news or press release category of the outlet, never in an advertising category. - Programme press releases are not advertising: they are not paid for and do not promote the sale of goods or services. That is why we do not label them as advertising. - Links in the press release are published with the nofollow attribute. - Below each press release we add, without a link, the line "Comunicat transmis de {organizație}, publicat gratuit prin programul Comunicate de interes public." ("Press release submitted by {organisation}, published free of charge through the Public Interest Press Releases programme."), in Romanian on the outlet. The organisation name is the one confirmed at enrolment. The line cannot be removed or changed. - Press releases published as paid content, including with the discount code, do not carry this line. - You request a correction to a published press release from the app, and it goes through approval again. If we reject it, we tell you why by email (section 13), and the published press release stays as it was. - You can ask at any time for a press release published through the programme to be deleted, from the app with a deletion request, or at contact@comunicate.eu. The form asks for a few words about the reason, but we do not refuse the request because of the reason.

Artificial intelligence. While the organisation has an application under review, is in the programme or has its participation suspended, its articles do not go through artificial intelligence services: not automatically, not those brought into the app through document import or email import, and not when you ask for it. The fields you do not fill in yourself, such as the search engine title and description, the keyword, the article address or the tags, are filled in by the app by fixed rules, from your text. The editor's artificial intelligence buttons for filling in fields and for suggestions are not shown to programme organisations, and the app refuses such requests. The only exception is paid services you order separately, such as having a text written, which follow the Privacy Policy.

13. How we decide and how we explain our decisions

A person decides. Every application and every press release is reviewed by a person on our team. We decide carefully, objectively and proportionately, with due regard to freedom of expression and to the public interest of the information.

What is automatic. Besides the limits in sections 8 and 12, which the form applies by itself (including when an outlet cannot currently receive programme press releases), four decisions are automatic:

- the enrolment form does not accept the application in the cases listed in section 7; - until the date shown, the enrolment form does not accept an application for a tax number whose participation was terminated with a refusal of new applications (section 20), from any account; - the publishing form does not accept a press release with more than 3 links to other websites; - the monthly ANAF recheck can pause the monthly top-up until a person decides.

In the first three cases we show you the reason at once. In the fourth, the Programme page shows that the month's publications are waiting for our team's check. If you think such a decision is wrong, write to us from Support: a person checks it. Other automated tools only flag what needs careful reading, for example election-related terms, commercial content, EU project announcements, too many links, or similarity with a press release sent earlier. The flags do not decide on their own: they do not approve or reject anything.

What we publish. We approve and publish press releases that comply with these rules on the outlets chosen, within the limits in section 8. The outlets are ours and we publish under our editorial responsibility. That is why we may also refuse a press release that, without breaking a specific rule, would break the law or infringe someone's rights. We may remove a published press release if we later learn that it breaks these rules or the law.

We always tell you why. When we reject an application, a press release or a correction to a published press release, or when we suspend or end participation, we send you an email, and you also see the decision in the app. When we hide or remove a published press release, or give you notice of a termination (section 20), a person on our team writes to you from Support with a reasoned message. The message contains:

- what we decided and, for a press release, for which outlets; for a suspension, what needs to be done to lift it; - the facts we relied on, written by the person who decided, including whether we acted on a notice or on our own review; - the ground: the section of these rules or, for illegal content, the legal provision breached, and why; - whether the decision was taken automatically or by a person and, if automated tools flagged anything beforehand (for example election-related terms, commercial content, an EU project announcement or the percentage of similarity with an earlier press release), what the flags were; - how you can ask for a review.

For all these decisions we follow the statement-of-reasons rules in Article 17 of Regulation (EU) 2022/2065.

Review. You can ask for any such decision to be reviewed within 6 months of being notified, from Support or, if you no longer have access to the account, at contact@comunicate.eu. A person on our team reads and decides the request, where possible someone other than the person who took the decision. We give you a reasoned answer, usually within 5 working days. The review is free and does not prevent you from going to court.

14. Press release content and the rights in it

What the organisation guarantees. For each press release, the organisation guarantees that:

- it has the right to publish the text, the images and the other materials, because they are its own or it has their authors' consent; - the information is accurate on the date it is sent; - it complies with the personal data rules in section 15; - the press release does not break the law or infringe anyone's rights: honour, reputation, private life, image, copyright or trade mark rights.

The data in the application must be true and kept up to date.

The rights stay yours. The press release and its materials remain the property of the organisation or of their authors. You can publish the same press release anywhere else.

What you allow us. By sending a press release, the organisation grants us, on a non-exclusive basis and free of charge, the right of reproduction and the right of communication to the public, including making available to the public (art. 13(a) and (f) of Law no. 8/1996), over the press release and its materials, for:

- publication on the chosen outlets and in their archives; - the RSS feeds and listing pages of those outlets; - the organisation's monthly report.

The grant applies online, in every country, for as long as the press release remains published. For the copies we keep as evidence, it applies for as long as we keep them under the law. We do not pass it on to anyone else. The technical providers that help us publish (hosting, content delivery) use it only for us. The grant serves only the publication you ask for. It is not a payment for the programme and gives us no other rights in the content.

What we may adapt. Formatting, image size and cropping, the title and description for search engines, the summary, the tags and the alternative text of images, which we may generate automatically; for programme organisations, without artificial intelligence services (section 12). We add the programme line and the nofollow attribute. We do not change the meaning of the text and we do not attribute to the organisation statements it did not make. We make no other changes without your agreement.

Complaints from others. Anyone who considers that a press release published through the programme infringes their rights or the law may write to us at contact@comunicate.eu, with the link and the reason. While we review it, we may hide the press release. We tell you what was complained about. We disclose the complainant's identity only if strictly necessary. Except in obvious or urgent cases, we give you 3 working days to reply before we decide. We inform the competent authorities of activities or information that appear to be unlawful, as required by art. 16(1) of Law no. 365/2002.

Recourse. If a third party obtains compensation from us because of a press release or materials sent by the organisation in breach of the guarantees above, the organisation reimburses the amounts we were ordered to pay by a final court judgment or under a settlement it agreed to, together with reasonable legal costs. We notify you as soon as we receive the claim, let you take part in the defence and do not settle on the organisation's behalf without its agreement, which it may not refuse without reason. The organisation is not liable for the part of the damage due to changes we made or to our own fault.

15. Personal data

How we use the data of the people who apply, of the person at the official address and of the people who appear in press releases, the legal bases, how long we keep the data and the rights of those people are set out in Annex 1. This section sets out the obligations of the organisation and of us regarding the data in press releases.

Personal data in press releases. The organisation and we are jointly responsible for publishing the press release, as joint controllers (art. 26 of Regulation (EU) 2016/679, the "GDPR").

The organisation:

- puts in the press release only the personal data needed and has a legal basis for each: the person's consent, legitimate interest or, for public institutions, the performance of a task in the public interest (art. 6(1) GDPR); - tells the people who appear in the press release that it will be published, and where; - keeps the originals of the written consents it relies on, emails them to us before approval where the rules below require it, and shows them to us again on request, within 5 working days; - tells us at once when a person withdraws their consent or asks for their data to be removed; - reimburses us for compensation we paid a person for a breach that falls within its share of responsibility (art. 82(5) GDPR), on the terms of the recourse in section 14.

We:

- read every press release before publication and refuse it if it breaks the rules below; - publish it on the outlets of our own network and keep it secure; - receive at contact@comunicate.eu the requests of people who appear in press releases and inform the organisation of those that concern it; - publish the essence of this arrangement in Annex 1.

Children. A child under 18 may appear in a programme press release, by name, in an image or through details by which they can be recognised (such as class, school, town and age), only if:

- their parents or, where applicable, their legal representative have given written consent to the publication of that press release on our outlets, and a child aged 14 or over has also given their own consent; - you email us the consent at contact@comunicate.eu, with the title of the press release, before approval; without it, the press release is rejected.

The legal bases: a child has the right to the protection of their public image and of their intimate, private and family life (art. 27(1) and (2) of Law no. 272/2004 on the protection and promotion of the rights of the child), everyone has the right to their own image (art. 73 of the Romanian Civil Code), and the legal acts of a minor aged 14 or over are concluded by the minor, with the parents' approval (art. 41(2) of the Civil Code). Even with consent, we do not publish press releases in which a child can be recognised if they concern a vulnerable situation: children who are victims of a crime, of abuse, neglect or violence, their health, sanctions, children in the special protection system, or children in conflict with the law (art. 87 of Law no. 272/2004 prohibits making public any data on criminal acts committed by a child who is not criminally liable). Children may not be used or exposed in order to obtain advantages for the organisation or to influence the decisions of authorities (art. 27(4) of the same law). Photos in which children cannot be recognised (from a distance, from behind or with faces blurred) need no consent.

Other data that cannot appear in a programme press release:

- data about the health of a person who can be recognised, including about patients, and the other special categories of data (art. 9(1) GDPR): racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, sex life or sexual orientation. Exception: the person is an adult and has given explicit written consent to publication on our outlets (art. 9(2)(a) GDPR), and you email it to us at contact@comunicate.eu before approval; - personal numeric codes, identity document numbers, home addresses, personal phone numbers; - data about criminal or administrative offences of individuals.

Documents you send us. You email the written consents above and the letter of representation in section 7 to contact@comunicate.eu; Support in the app accepts only text. We keep no copies of them. A person on our team records in the app which document they saw, its date and who signed it: for the letter of representation, the signatory's name and position; for consents, the capacity of the person who signed (for example parent, legal representative or the person concerned), without copying the child's data. We delete the email with the document within 30 days of the decision at the latest. The organisation keeps the original and shows it to us again on request, for example when we receive a complaint, within 5 working days.

Requests from people in press releases. If someone who appears in a press release asks us to remove their data and the request is justified, we may remove the name, the image or the whole press release without the organisation's agreement. We tell you by email. If parents withdraw their consent for a child, we remove the child's name and image.

16. Liability

The programme is free, and the publication of each press release remains our editorial decision, under section 13. We do not guarantee publication on a particular date or on a particular outlet, and we do not guarantee traffic, indexing or search engine rankings.

Towards the organisation we are not liable for:

- not publishing, delaying or removing a press release in accordance with these rules; - temporary unavailability of the outlets or of the app; - lost profits and other indirect damage.

We are, however, liable for damage caused intentionally or through gross negligence; that liability cannot be excluded or limited (art. 1355(1) of the Romanian Civil Code). Nor does the limitation affect damage to physical or mental integrity or health (art. 1355(3)) or our obligations regarding personal data.

Towards other people, each of us is liable according to the law. Between the organisation and us, the recourse in section 14 applies.

17. Free publications

Programme publications are free of charge and reserved for the organisation's own use. They cannot be sold, transferred to another organisation or account, or exchanged for money or other services, and they do not carry over from one month to the next. We issue no invoice for them.

18. Discount code for NGOs

Approved NGOs receive a 30% discount code for paid publications on the outlets of our own network, for example for announcements of projects funded by EU funds. You receive the code in the approval message, and only your organisation can use it, at most 100 times. The discount appears on the invoice. Schools, universities, hospitals and city halls do not receive a discount code, nor do private or denominational schools and universities registered as associations or foundations.

The code stops when participation is suspended or ends, and restarts if participation is reinstated. It may not be used for political advertising.

Paid publications, with or without the code, are governed by the Terms and conditions for advertisers, not by these rules.

19. The messages we send you

By email and in the app we write to you about your application (including the confirmation that we received it), your press releases, the yearly reconfirmation, suspension and termination, changes to these rules and the end of the programme. These are service messages about your application and participation, and they cannot be turned off in the notification preferences: you also receive them when a decision takes you out of the programme (for example the rejection of the application or a termination).

Some of them are always sent by email and cannot be turned off in the account's notification settings: the confirmation of the application, approval, rejection of the application, suspension, termination, rejection of a programme press release or of a correction to it, the yearly reconfirmation reminder and the representation confirmation message sent to the official address. The notification settings show them as mandatory.

We send you offers for paid publications by email only if you separately ticked, in your account, that you want to receive them. You can opt out at any time from your account's notification settings.

20. Withdrawal, suspension, termination

Withdrawal. You can withdraw at any time from the programme page, with immediate effect. Programme press releases awaiting approval are no longer approved. Remaining publications are lost, and the discount code stops. Press releases already published stay published; you can ask for their deletion at any time (section 12).

You can apply again, with a new verification, at least one day after withdrawing. If you withdrew while participation was suspended, you can no longer send a new application yourself for the same tax number, from any account: write to us from Support. Once the reason for the suspension has been removed, our team either reinstates participation or unblocks the tax number so that you can send a new application.

Suspension. We may suspend participation, with reasons as set out in section 13, if:

- a press release or the data in the application breaks these rules; - ANAF no longer finds the tax number or shows the organisation as deregistered, tax-inactive, in dissolution, liquidation, bankruptcy, insolvency, reorganisation, with its activity suspended or ineligible; - the representation can no longer be confirmed at the yearly reconfirmation.

A suspension takes effect when it is notified. While it lasts, no programme press releases can be sent, press releases awaiting approval are no longer approved, and the discount code is stopped. Published press releases stay published. The suspension ends when its reason has been removed and a person reinstates participation.

Termination at our initiative. Termination is always decided by a person on our team. It takes effect immediately, from the date we record it in the app, and we notify you of it by email, with the reasons set out in section 13. On the Programme page, participation is shown as ended.

Termination with notice. We may also end an organisation's participation without any breach, with 30 days' notice. A person on our team sends you the notice from Support, with the reason. After the 30 days we record the termination.

Automatic termination. Participation ends automatically, without formal notice of default and without court intervention, on the date of our reasoned decision, if the organisation:

- a) gave false data at enrolment or reconfirmation, including about the right to represent it; - b) sent election campaign material through the programme or, after we rejected one of its press releases as political advertising, sent political advertising again; - c) presented commercial content through the programme as public-interest information, hiding its commercial nature; - d) sent a press release for which it did not hold the rights and which led to a final judgment or a settlement against us; - e) let another organisation use the programme through its account; - f) repeated a breach after a suspension.

Suspension not lifted. If the reason for a suspension has not been removed within 90 days, we may end participation, again by the reasoned decision of a person on our team.

Effects of termination. Termination has the same effects as withdrawal: programme press releases awaiting approval are no longer approved, remaining publications are lost, and the discount code stops. Press releases already published stay published.

A new application after termination. After a termination on grounds a) to f), we may refuse a new application from the organisation for 12 months from the termination. When we decide this, the termination email and the Programme page show the date until which the app no longer accepts a new application for the same tax number, from any account. If the review (section 13) finds in your favour, we cancel the termination and your participation resumes, or we lift the refusal so you can send a new application. If we have not decided a refusal, you can send a new application, with a new verification, at least one day after the termination.

End of the programme. We may end the programme for all organisations by announcing it by email at least 30 days in advance. Until the end date, the programme runs normally: press releases sent by then are reviewed and, if approved, published. The discount code remains valid until the same date. Ending the programme does not lead to the removal of published press releases.

What survives termination. For press releases already published, the publication grant, the organisation's guarantees, the recourse and the data rules remain in effect.

21. Changes to these rules

1. We may change these rules only for valid reasons: changes in the law or requirements of authorities, changes to the outlets or the app, prevention of abuse, or changes to the programme's limits. 2. We email you the text of the new version and a summary of the changes at least 30 days before it takes effect. 3. This notice period does not apply to changes that are solely in your favour, such as more publications or outlets, or to changes required by law or by an authority within a shorter period. We apply these from the date given in the notice and tell you the reason. 4. If you do not agree, you can withdraw at any time, without any consequence. If you send press releases through the programme after the new version takes effect, you accept it, subject to point 7. 5. Press releases approved earlier are published on the terms under which they were approved. 6. We keep all versions of these rules, with their effective dates, and send them to you on request. 7. If a new version adds or worsens clauses of the kind listed in section 23, we ask you to accept them expressly again, with a separate tick box, before the first press release sent after it takes effect. Until then, the previously accepted version applies to those clauses.

22. Governing law, disputes and other documents

The agreement is governed by Romanian law.

If a disagreement arises, write to us first at contact@comunicate.eu; we will try to resolve it together. If we do not succeed, the dispute is heard by the Romanian courts that have jurisdiction under the law.

Anything not covered here is governed by the Terms and conditions for advertisers (the account, paid publications), and data by the Privacy policy, supplemented for the programme by Annex 1. If the general terms say something different from these rules, these rules apply to the programme. In particular, the clause in the general terms that limits our liability to the amount paid does not apply to the programme, nor does the clause that chooses the courts of our registered office.

If a clause in these rules is invalid, the others remain valid.

23. Clauses you accept expressly

With the second tick box at enrolment, separate from the acceptance of these rules, you expressly accept, within the meaning of art. 1203 of the Romanian Civil Code, the clauses in:

- sections 8 and 17: unused publications do not carry over from one month to the next and are lost when you leave the programme; - section 13: our right to reject press releases and to remove published press releases; - section 16: the limitation of our liability; - section 20: suspension and termination of participation, including automatic termination without formal notice of default and without court intervention, and the refusal of a new application for 12 months; - section 21: changes to these rules and acceptance of the new version by sending press releases; - section 22: the governing law.

The text of the tick box is: "I expressly accept, on behalf of the organisation, the clauses in section 23 of the rules: unused publications do not carry over and are lost on leaving (s. 8 and 17); rejection and removal of press releases (s. 13); limitation of liability (s. 16); suspension and termination of participation, including automatic termination and refusal of a new application for 12 months (s. 20); changes to the rules and acceptance of a new version by sending press releases (s. 21); the governing law (s. 22)."

Version 1.0 of these rules takes effect on the date it is published on the website, shown above the text.

Questions: contact@comunicate.eu.

Annex 1. How we use personal data in the programme

This annex is part of the rules. For the programme, it supplements the Comunicate.eu Privacy policy (https://comunicate.eu/en/legal/confidentialitate), which also applies here to everything not covered below, for example the account data. It concerns the people who send the application, the person at the organisation's official address and the people who appear in press releases published through the programme.

Who is responsible for the data. ARC MEDIASOFT SRL, Aleea Botorani nr. 6, bl. V83, sc. 3, et. 5, ap. 79, sector 5, Bucharest, Romania, tax code RO32431001. For any question about your data: contact@comunicate.eu. For the publication of press releases, we are responsible together with the organisation that sends them, as joint controllers (art. 26 GDPR).

1. Who applies. When an organisation applies, we process the name and email address of the person who sends the application, the organisation's official address and website, the note in the application and, if you email it to us, the letter of representation, with the name, position and signature of the legal representative. We keep no copy of the letter: we record in the app that we saw it, its date and the signatory's name and position, and we delete the email with the letter within 30 days of the decision at the latest. We use them to check that the application really comes from the organisation and so that we do not publish on behalf of someone who has no right to. The participation agreement is concluded with the organisation, not with you personally. That is why the basis is the legitimate interest, ours and the organisation's, in preventing impersonation and abuse (art. 6(1)(f) GDPR). Without these data we cannot check the application, and the organisation cannot join the programme. We do not ask for copies of identity documents or for the personal numeric code (CNP). Do not include them in the letter; if they appear anyway, we do not record them anywhere.

2. Acceptance of the rules and of the clauses. For each of the two tick boxes at enrolment we keep the version accepted, the account, the person, the date and time, the IP address and the browser type. We also keep the time and IP address from which the representation was confirmed and, for each press release, the tick of the declaration in section 11, with the date and IP address. We use them to be able to prove who accepted the rules, who requested each publication and what they declared, including in court. Basis: legitimate interest (art. 6(1)(f) GDPR). Accepting the rules is not consent under the GDPR, so it cannot be withdrawn; if the organisation leaves the programme, the record stays as evidence for the period in point 9.

3. The person at the official address. We send the confirmation link or code to the organisation's official address, together with the name and email address of the person who applied, so that the recipient knows who is asking. The official address was given to us in the application by someone from the organisation, or we found it ourselves on the organisation's official website or in a public register. If the address belongs to a person, for example the head teacher, we process the email address and, where it shows it, the name, only to confirm the representation. Basis: the legitimate interest, ours and the organisation's, in preventing impersonation (art. 6(1)(f) GDPR). The message tells the recipient why they received it and links to this annex. It is a service message, with no offers.

4. The ANAF check. We check the tax identification number in the public registers of ANAF, the Romanian tax authority, when the organisation applies and then once a month. We send ANAF only the tax number. The data of an association, foundation or public institution (name, address, tax status) concern a legal person and are not personal data. They become personal data when the number belongs to an authorised self-employed person or to a sole or family enterprise; the basis is then also legitimate interest, and the source is ANAF's public register.

5. What is decided automatically. The application form cannot be submitted in the cases listed in section 7: for example, if ANAF does not find the tax number or shows that the organisation is a company or is deregistered. The check concerns the organisation, not the person filling in the form, and we show you the reason at once. If ANAF or our classification is wrong, write to us from Support: a person repeats the check and answers you. The monthly check only pauses the monthly top-up until a person looks at the case. Approval, rejection of a submitted application, suspension and termination are always decided by a person. For press releases, automated tools only flag what needs careful reading (section 13). We take no decision about you, as a person, based solely on automated processing that produces legal effects (art. 22 GDPR).

6. People who appear in press releases. Press releases are written by the organisations. Some name people or show their photo: a doctor, a teacher, a volunteer, a guest. When we publish such a release on our outlets, the organisation and we are jointly responsible for publishing it, as joint controllers. We have divided the tasks as follows:

- the organisation chooses which data go into the release, has a legal basis for them, tells the people concerned that they appear in a published release and keeps the originals of the written consents; - we read every release before publication and refuse anything that breaks the rules, publish it on the outlets of our own network, keep it secure and answer your requests.

Our basis for publishing is the legitimate interest in making public-interest information known, such as the work of a school, a hospital, a city hall or an NGO (art. 6(1)(f) GDPR). For special categories of data, the basis is the person's explicit consent (art. 9(2)(a) GDPR). We receive the data from the organisation that sends the release. We do not have the contact details of the people in the releases and cannot notify each of them; that is why we make this information available to everyone here (art. 14(5)(b) GDPR).

Through the programme we do not publish:

- data or images by which a child under 18 can be recognised, except with the written consent of the parents or legal representative (and of a child aged 14 or over), emailed to us before approval, and never when the release concerns a vulnerable situation of the child (section 15); - data about the health of a person who can be recognised, including about patients, and the other special categories of data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, sex life or sexual orientation, unless the person is an adult and the organisation emails us that person's explicit written consent to this publication before approval; - anyone's personal numeric code, identity document number, home address or personal phone number; - data about criminal or administrative offences of individuals, or accusations against them.

If you appear in a press release, write to contact@comunicate.eu if you want to be removed from it or if something is wrong. You may write to us or to the organisation: you can exercise your rights against either of us (art. 26(3) GDPR). When the request is justified, we remove the name or image, or the whole release, and inform the organisation. We leave the release unchanged only when the information is necessary for exercising the right of freedom of expression and information (art. 17(3)(a) GDPR); in that case we tell you why.

7. Who sees the data. The application data are seen only by the team members who decide applications and those who answer in Support; the team also receives them by email. The technical providers that help us host the app and deliver and protect the pages may process them, only for us and on our instructions. We send emails from our own server. The press release, with the data in it, becomes public on the outlets chosen by the organisation. We give data to authorities only when the law requires us to.

8. Data outside the European Economic Area. The app is hosted in Germany, and we send emails from our own server. The pages of the app and of the outlets are delivered and protected by Cloudflare, Inc., of the United States, which may process outside the European Economic Area the technical data of visits (for example the IP address) and the content of the pages delivered, including data in forms and in published press releases. Cloudflare, Inc. is certified under the EU-US Data Privacy Framework, for which the European Commission has adopted an adequacy decision (art. 45 GDPR). The certification can be checked in the public list at dataprivacyframework.gov.

Texts of programme organisations do not go through artificial intelligence services (section 12), so they do not reach providers of such services. Paid services you order separately, such as having a text written, follow the Privacy Policy.

9. How long we keep the data.

- While the organisation has an application under review, is in the programme or has its participation suspended, we keep the data in points 1 to 3. - An application rejected or withdrawn without ever having been approved: 12 months after the decision or the withdrawal, we anonymise the data about people. - Participation ended after approval, by withdrawal or termination: 3 years after the withdrawal or the termination decision, we anonymise the data about people. The 3 years are the general limitation period under Romanian law (art. 2517 of the Civil Code). If a dispute starts before that, we may keep separately, until it is finally settled, only the data needed for the establishment, exercise or defence of legal claims. - When we anonymise, the app deletes: the official address and the address to which the confirmation was sent, the note in the application, the fingerprint of the confirmation link or code; the IP addresses, browser types and email addresses in the programme's audit log, including in the records of the declarations made with each press release; the IP addresses and browser types in the record of the acceptance of the rules; the content of the Support ticket opened automatically with the application; the programme emails sent to the users of the organisation's account and to the official addresses, kept in our email sending system, if they have not already been deleted earlier; and the notices about the application received by the team in the app. - The notices about the application that the team received by email are deleted from the team's mailboxes by a person on our team, after the same periods. - Even after anonymisation, we keep the organisation's tax number, name, category and status, the decision and its reason and, after a termination, the date until which we refuse a new application. These are data about the organisation, not about people, and we need them to apply the rules in section 20, for example the refusal of a new application for 12 months or unblocking the tax number after a withdrawal during suspension. - Our team's note about the letter of representation (the date of the letter and the name and position of the legal representative who signed it) stays in the programme's audit log even after anonymisation, as proof that we checked who requested publication on behalf of the organisation. - Confirmation links and codes: we do not keep them in clear text, only a fingerprint of them, and they can no longer be used after 7 days or after confirmation. - Published releases: for as long as the organisation does not ask for their deletion and no justified reason to remove them arises. - Documents sent by email (the letter of representation, written consents for children or for health data): we keep no copies. A person on our team deletes the email with the document within 30 days of the decision at the latest. The original stays with the organisation. - The note about a written consent (which document we saw, its date and the capacity of the person who signed it, without the child's data) is written by the person who approves the press release and stays in the approvals log for as long as we may need it as proof that the publication had consent. At the request of the person or the parents, we delete it once we no longer need it for the defence of a legal claim. - The Comunicate.eu account data (the users' names and email addresses) are kept as set out in the Privacy policy.

10. Your rights. You have the right of access, rectification, erasure and restriction of processing, under the conditions of the GDPR. Write to contact@comunicate.eu; we answer within one month at the latest (art. 12(3) GDPR). If you are not satisfied, you can complain to the Romanian data protection authority, the National Supervisory Authority for Personal Data Processing (dataprotection.ro).

Right to object. You may object at any time, on grounds relating to your particular situation, to the processing in this annex based on legitimate interest (art. 21(1) GDPR). We stop, unless we demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or we need the data for the establishment, exercise or defence of legal claims.