bGuru Terms of Service

Last updated: 2026-06-06

§0 Plain-language summary

bGuru is a free social network for sports predictions. You make picks, build reputation, join groups, climb leaderboards. No money changes hands between you and bGuru or between users. This is not a betting product. The only currency is your skill rating and reputation. You must be at least 16 to use bGuru — see §3.

The rest of this document is the legal contract between you and bGuru. We have tried to keep it short and readable. If you are a consumer in the EU, the UK, the US, or any other jurisdiction with mandatory consumer-protection law, your local statutory rights apply on top of this contract — see §15 for how that works.

§1 Definitions

• Account — a registered bGuru profile tied to a verified email and a unique display name.
• Pick / Prediction / Tip — a forecast about the outcome of a sports event you submit through bGuru.
• Conviction Score — a measure of how committed you are to a Pick across the contexts in which you submit it.
• Group — a private or app-curated set of users that compete on a separate leaderboard.
• Leaderboard — a ranking based on accumulated reputation points.
• Tipster — a user whose Picks have measurable accuracy.
• Premium Tipster — a user selected for inclusion in a paid platform tier under §8.
• Content — anything you submit through the Service: Picks, comments, profile information, group names, group descriptions, reactions.
• the Service — the bGuru mobile app, mini-site, and back-end systems.
• bGuru / we / us / our — see §17 for the controlling entity and contact details.

The Service does not offer gambling mechanics such as bets, wagers, stakes, payouts, winnings, house odds, or anything of money's worth as a reward.

§2 Eligibility & registration

To register for bGuru, you must (a) be at least 16 years old; (b) provide a valid email address and select a unique display name conforming to the format rules in our help documentation; (c) accept these Terms; and (d) reside in a jurisdiction in which bGuru is available (see §14).

You may hold only one Account. Multi-accounting — for the purpose of leaderboard manipulation, evading a suspension, or any other reason — is a breach of these Terms and may result in termination under §9.

You are responsible for keeping your login credentials confidential and for all activity that occurs under your Account.

United States (COPPA hard-block). Users under the age of 13 may not register for or use the Service, as required by the Children's Online Privacy Protection Act (COPPA, 15 U.S.C. §§ 6501–6506) and the FTC's implementing rules (16 CFR Part 312). If bGuru obtains actual knowledge that a registered user is under 13, we will promptly delete that account and any associated personal information without further notice; if that user has inadvertently been charged for any paid tier available at the time, we will process a refund in full in accordance with the applicable payment processor's refund procedures and any mandatory refund rights under applicable law. bGuru does not employ cookie-fingerprinting, device-fingerprinting, or any other mechanism designed to identify users as minors for tracking or targeted-advertising purposes. bGuru's obligation to hard-block under-13 users applies regardless of any parental consent obtained outside the Service; no parental consent mechanism can authorise a sub-13 account under these Terms.

§3 Age eligibility

bGuru sets a flat minimum age of 16 in all jurisdictions in which the Service is available. There is no parental-consent path below 16 at this version of the Service. A registration attempt by a user under 16 is rejected at signup. The 16-year minimum is the same in every market in which bGuru is offered; bGuru does not vary the minimum age by jurisdiction.

The 16-year minimum was chosen as the lowest single age that satisfies, in a single rule, the applicable information-society-services consent thresholds in every major launch market — including the GDPR Art. 8 default of 16 across all EU/EEA member states (Reg. (EU) 2016/679), the UK Data Protection Act 2018 s. 9 threshold of 13, the United States COPPA threshold of 13 (15 U.S.C. § 6501(1)), the Israeli Privacy Protection Law 1981 threshold of 13, the Quebec Act respecting the protection of personal information (Law 25) §4.1 threshold of 14, the South Korean Youth Protection Act threshold of 14, and the operative threshold under the Australian Online Safety Amendment (Social Media Minimum Age) Act 2024 (16). The 16-year minimum is at or above every one of these, so no per-jurisdiction parental-consent flow is required at this version of the Service.

Under-18 protections that still apply at 16+. Several jurisdictions impose protections on users under 18 that operate independently of the consent-age threshold; bGuru honours these for its 16- and 17-year-old users:

• United Kingdom (ICO Children's Code). The Information Commissioner's Office Age Appropriate Design Code applies to any service likely to be accessed by children, defined as under-18s, regardless of the user's individual age of consent. bGuru honours the Code's data-minimisation principles for users aged 16 and 17: we do not carry out profiling for the purpose of targeted advertising; we do not serve behavioural or interest-based advertising to users under 18 at any version of the Service. bGuru does serve non-personalized contextual ads (via Google AdMob NPA mode) to users including those aged 16–17; for those users bGuru applies Google's current age-restricted ad-treatment settings available in the Google Mobile Ads SDK, ensuring no IDFA or GAID is read and Google applies its own child-directed ad protections. Default privacy settings for under-18 users are set to the highest level of protection consistent with the Service's functionality.
• United States (state minor-data laws). California SB-976 (Protecting Our Kids from Social Media Addiction Act, 2024 — "KOSMA"), New York's Stop Addictive Feeds Exploitation (SAFE) for Kids Act (2024), Maryland's Minor Online Data Protection Act (MODPA), and Colorado's CPA minor-data provisions restrict addictive-design and behavioural-targeting features for users under 18. These laws apply to services that qualify as "social media platforms" using algorithmic content recommendation. bGuru does not currently operate an algorithmic content-recommendation feed, so these laws do not currently apply to bGuru, but bGuru's no-behavioural-targeting-of-under-18s posture means we would satisfy the substantive obligations even if a future feature brought the Service in scope. For the avoidance of doubt: bGuru does NOT serve behavioral, interest-based, or profiling-based advertising to any user under 18 at any version of the Service. bGuru does serve non-personalized contextual ads (Google AdMob NPA mode) to all users including those aged 16–17; for those users bGuru applies Google's current age-restricted ad-treatment settings available in the Google Mobile Ads SDK, ensuring IDFA and GAID are not read for those users. This NPA contextual-ad posture satisfies KOSMA's and MODPA's prohibitions on processing under-18 personal data for targeted advertising.
• European Union / EEA — Digital Services Act + child-safety regimes. Member-state child-safety regimes (and DSA Art. 28 protection of minors) apply to under-18 users independently of GDPR Art. 8. bGuru applies the same no-behavioural-targeting-of-under-18s posture as in the UK and US, irrespective of which member state the user is resident in. DSA Art. 28(2) prohibits profiling-based advertising to known minors; bGuru satisfies this because (a) bGuru operates AdMob in NPA (non-personalized) mode, which does not build a behavioral profile for anyone, and (b) bGuru applies Google's current age-restricted ad-treatment settings available in the Google Mobile Ads SDK for users registered as 16 or 17, providing a hard enforcement signal to Google's ad-serving systems. Non-profiling contextual ads consistent with NPA mode do appear to users aged 16–17; this is consistent with DSA Art. 28(2) because no profiling occurs.

Deferred markets (parental-consent infrastructure required — v1.1). Two jurisdictions cannot be opened at the 16+ baseline because their applicable regimes require verifiable parental consent for users above 16:

• Brazil — the Digital ECA (Law No. 15.211/2025) requires parental consent for all users under 18, so a 16+ baseline does not eliminate the requirement for the 16–17 band.
• India — the Digital Personal Data Protection Act 2023 requires verifiable parental consent for all users under 18, so a 16+ baseline does not eliminate the requirement for the 16–17 band.

bGuru is not available in Brazil or India at this version of the Service. Both markets will be opened in a future version once a verifiable-parental-consent flow has been implemented.

§4 The contests bGuru offers

bGuru is a free skill-based prediction contest. There is no entry fee, no stake, and no prize of money or money's worth. The only currency is your skill rating.

§4.1 What bGuru is

bGuru offers a sports-prediction product modelled on long-running free-to-play pick'em formats — most familiarly, the kind of office-pool or fan-engagement contest where participants forecast match outcomes for fun, recognition, and ranking, with no money on either side of the contest. Users submit a Pick on an upcoming sports event, choose how confident they are by participating across multiple contexts (global leaderboard, groups they belong to), and accumulate reputation points based on accuracy and a conviction multiplier. The leaderboard is a public ranking of reputation points within the relevant context (global, country, league, group, season). At no point does a user pay to participate, transfer anything of monetary value to another user or to bGuru as a condition of participating, or receive anything of monetary value in return for a Pick or a leaderboard position. Reputation points cannot be redeemed, transferred, sold, or exchanged for anything of monetary value, and are extinguished if the Account is closed.

The optional paid tier described in §8 (Premium-Tipster bundling) does not change this analysis: it is a subscription to a content product, not an entry fee for a contest. Subscribers receive no advantage in the contest mechanics — no extra Picks, no boosted Conviction Score, no privileged access to outcomes.

§4.2 Jurisdiction-specific characterisation

bGuru is designed not to constitute gambling, betting, a lottery, fantasy sports, or a regulated prize contest in any jurisdiction in which it operates, because users do not pay an entry fee, stake anything of value, or receive any prize, payout, or transferable item of monetary value. The following sections describe how this product-design posture aligns with the specific statutory tests in our launch markets. They are descriptive of how the product is designed relative to those statutory tests; they are not a legal conclusion that the product is definitively outside any particular regulatory regime in any jurisdiction.

Israel (Penal Law 5737-1977 §225 + §227 / חוק העונשין, תשל"ז-1977 §§225, 227). Under Israeli law, a "prohibited game" (משחק אסור) under Penal Law §225 requires three cumulative elements: (i) a prize of money or monetary value that can be won, (ii) something of monetary value at stake or risked by the participant, and (iii) an outcome that depends substantially on chance. bGuru's product design is intended to fall outside all three elements: there is no prize of any kind (the only reward is a skill rating and leaderboard position, which have no monetary value and cannot be redeemed or transferred); there is nothing of monetary value at stake or risked (participation is free, no in-app purchase is required to submit a pick, and no value can be lost); and sports prediction is a predominantly skill-based activity. Even on the most generous interpretation of the chance prong, the prize-and-stake prongs are both absent by product design. The §227 "lottery" offence (הגרלה) equally does not apply by design: a lottery requires prize-and-consideration elements, neither of which is present.

United States (federal sweepstakes/lottery + UIGEA + state skill-contest regimes). Under United States federal law, bGuru is designed not to constitute a lottery, illegal sweepstakes, or unlawful gambling promotion. The three elements required under 15 U.S.C. § 1303, 18 U.S.C. § 1301, and the relevant anti-lottery provisions of 39 U.S.C. § 3005 — namely (i) a prize of money or money's worth, (ii) an outcome determined by chance, and (iii) consideration paid by the participant — are all absent from the Service by design: the Service offers no prize of any kind, participation is free with no entry fee or purchase required, and sports prediction is a skill-dominant activity. bGuru is also designed to fall outside the scope of the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA, 31 U.S.C. §§ 5361–5367), which prohibits the processing of payments connected to "bets or wagers." The Service does not constitute a "bet or wager" within the meaning of 31 U.S.C. § 5362(1): in particular, 31 U.S.C. § 5362(1)(E)(ix) expressly excludes from that definition participation in any game or contest in which participants do not stake or risk anything of value — precisely bGuru's product posture, since participation is free, no entry fee is charged, and no thing of value is staked or at risk. Across the 50 US states, the Service is designed not to meet the prize/consideration/chance triad common to state gambling statutes, because no prize of monetary value is offered and no consideration is required to participate. Several states — including Delaware, Iowa, Idaho, Montana, Nevada, and Washington — impose specific licensing or registration requirements on paid daily-fantasy-sports operators that accept entry fees and award cash prizes. Those requirements are not intended to apply to bGuru: bGuru charges no entry fee, awards no prize of money or money's worth, and is not a "fantasy sports" product within the scope of any applicable state fantasy-sports statute. bGuru's no-prize, free-entry product design is intended to place it outside the regulated gambling and regulated-fantasy-sports categories in all 50 states, the District of Columbia, Puerto Rico, and all US territories; in no case does bGuru offer, accept, or intermediate any transfer of money or thing of value as a result of a prediction outcome.

United Kingdom (Gambling Act 2005). bGuru is designed to fall outside the UK gambling regime. Under the Gambling Act 2005, "gaming" within the meaning of s. 6 requires the playing of a game of chance for a "prize"; "betting" within the meaning of s. 9 requires staking money or money's worth on an event outcome with the prospect of a corresponding return. bGuru is designed to satisfy neither definition: there is no prize of money or money's worth (the only reward is on-platform reputation and ranking), and no user pays or risks anything of financial value to submit a Pick. The prize-competition exemption in s. 14 and Schedule 2 of the Act (which exempts competitions in which participants demonstrate skill, knowledge, or aesthetic judgment) is noted for symmetry — bGuru's product design does not require that exemption because the prize element of s. 6 and s. 9 is not engaged in the first place. The product design therefore satisfies the tests that would otherwise attract Gambling Commission oversight. bGuru is separately subject to the UK Online Safety Act 2023 as a user-to-user service — illegal-content duties and child-safety risk-assessment obligations under that Act are addressed in the Community Guidelines and do not affect the non-gambling characterisation.

European Union / EEA (no harmonised EU gambling regime; per-member-state regimes). There is no single EU-wide gambling law; each member state operates its own regime. Across every EU and EEA member state, however, a regulated gambling activity requires at minimum the combination of a prize of monetary value and a stake or consideration surrendered by the participant. bGuru is designed to satisfy neither element: the Service is free to access and use, no entry fee or in-app purchase is required to submit a Pick or compete on any leaderboard, and no prize of money or money's worth is ever awarded — the only reward is your publicly visible skill rating and reputation score. The product design is therefore intended to fall outside the regulated gambling or gaming categories under each member-state regime. Two specific points merit mention: (a) in Belgium, the Belgian Gaming Commission has explored an "engagement-as-consideration" theory in the context of paid loot-box mechanics — bGuru has no paid mechanics, no purchased virtual currency, and no loot-box dynamic, and the theory as currently applied is limited to paid contexts, so bGuru's posture is designed to be unaffected; (b) in France, the SREN Act 2024 and JONUM Decree 60/2026 created a regime for monetisable digital objects (jeux à objets numériques monétisables), which requires a "financial sacrifice" by the participant — bGuru requires no financial sacrifice and issues no tradable or redeemable digital objects, so the JONUM regime is not intended to apply, and bGuru also falls outside the classic French gambling regime under Article L320-1 of the Internal Security Code on the same no-prize grounds.

Rest of world (AU / SG / CA / BR / ZA / JP / KR / IN). bGuru's product design is intended to fall outside the gambling regulatory regime in each of the following jurisdictions on the following bases: in Australia, bGuru's design is intended to qualify for the social-gaming exception under the Interactive Gambling Act 2001 (IGA) s. 8AA(1) — no money or money's worth is staked by participants and no money or money's worth is paid to participants as a result of participation; bGuru is designed not to constitute a "betting service" or "prohibited interactive gambling service" under the IGA, and the ACMA's 2025 ruling on paid prediction-market contracts (the Polymarket classification) is distinguishable because bGuru involves no monetary stake and no cash payout; in Singapore, bGuru is designed to fall within the exemption from the Gambling Control Act 2022 because participation requires no "payment for a chance" and involves no element of money's worth as consideration — consistent with the established pure-skill / no-consideration exemption recognised in Singapore gambling jurisprudence; in Canada, the Criminal Code Part VII (ss. 201–209) gambling provisions require a monetary stake and the prospect of a monetary prize — bGuru has neither by design, and the free-skill prediction structure is intended to place it outside the definition of a "common gaming house" or "lottery scheme" under s. 206; in Brazil, gambling and sports lotteries are regulated under Decree-Law No. 3.688/1941 (contravention prohibitions) and, for fixed-odds sports betting specifically, under Law No. 13.756/2018 as amended and operationalised by Law No. 14.790/2023 (which governs licensed fixed-odds sports-betting operators effective January 2025) — bGuru is not a licensed lottery or licensed betting operator, imposes no entry cost, and offers no prize or monetary return, so the product design is intended to place it outside both regimes entirely; in South Africa, the National Gambling Act 7 of 2004 requires an element of "stake" (something of value risked) and a "prize" (something of value won) — bGuru has neither by design; in Japan, the Penal Code Art. 185 (賭博罪) prohibits gambling defined as wagering things of property value on a contingency — bGuru involves no property of value as stake or reward and its design is intended to fall outside the prohibition; in South Korea, the Criminal Act Art. 246 requires the staking of property value on a contingency, and the Game Industry Promotion Act regulates games involving property-value exchange — bGuru involves neither property stake nor property-value outcome by design; and in India, the Public Gambling Act 1867 (and its state-level equivalents) requires a "stake" element, and the Supreme Court of India in K.R. Lakshmanan v. State of Tamil Nadu (1996) confirmed that contests of skill predominance are exempt — bGuru's reputation-and-skill-rating model is designed to be exempt on both the no-prize ground and the skill-predominance ground.

§4.3 Entertainment purpose — no gambling mechanics

The prediction activities, scoring mechanisms, leaderboards, reputation metrics, Verified Tipster designations, and all other features offered through the Service are provided for entertainment and amusement purposes only. They do not constitute gambling, betting, games of chance, a guarantee of any outcome, financial advice, or financial activity of any kind. No stake, entry fee, or payment is required to participate in any contest or leaderboard. No money, goods, services, or anything of financial or tangible value is awarded to any user as a result of their Picks or leaderboard position.

For the avoidance of doubt: the Service's global scoring formula applies decimal odds as a mathematical ranking coefficient that measures how hard a correct prediction was to make — it is not a wager, does not reflect any bet placed or accepted, and does not cause any money to change hands. A user who makes every correct prediction possible still receives only a leaderboard rank and a reputation score. Neither of those has exchange value, instrumental value, or any real-world monetary significance.

Note on what protects bGuru: the protection this clause provides is corroboration of good-faith intent, not a legal defence in itself. What places the Service outside any gambling classification in any jurisdiction is the substance of the product design — the complete absence of any prize, stake, entry fee, coin, virtual store, or "benefit" with real-world value. This clause states that substance in plain terms; it does not create that substance. If the product design were ever changed to add a benefit of real-world value (for example, a virtual coin redeemable for physical goods, a cash prize, or a paid contest), this clause would not insulate the Service from reclassification. Any such product change must be reviewed against applicable gambling law before implementation.

§5 User-generated content & license to bGuru

You retain ownership of the Content you submit. By submitting Content, you grant bGuru a worldwide, non-exclusive, royalty-free, sublicensable licence to host, store, reproduce, display, distribute, adapt, and use that Content for the purpose of operating the Service and any successor or related service. The licence is perpetual with respect to Content that has been distributed to other users (for example, a Pick that has appeared on a leaderboard or in a group), and terminates with respect to Content you have not distributed to other users when you delete that Content or your Account.

You represent that the Content you submit is yours to license under these terms and does not infringe the rights of any third party.

Premium-Tipster bundling. If you are selected for inclusion in a paid Premium-Tipster tier under §8, the licence above continues to apply, and the Premium-Tipster bundle is treated as part of the Service. Selected users will be notified before any of their Picks are made available to paying subscribers, may opt out at any time, and receive the in-platform benefits described in §8. No cash compensation is owed to any selected user at MVP launch; the roadmap to any future revenue-share programme is described separately and is not part of these Terms.

§6 Acceptable use

You agree not to use the Service to: harass, threaten, dox, or impersonate any person; manipulate any leaderboard or scoring mechanic, including by creating multiple Accounts (multi-accounting) or coordinating with others to inflate a ranking; submit Picks via any automated means or any tool not provided by bGuru; scrape, mirror, or systematically reproduce any part of the Service or its data; reverse-engineer the prediction engine or the scoring system except to the extent expressly permitted by mandatory local law; or otherwise breach our Community Guidelines, which are incorporated into these Terms by reference.

bGuru may, at any time and without notice, remove Content that breaches these Terms or the Community Guidelines.

§7 Predictions, scoring, leaderboards

Picks are scored using a conviction-weighted formula. For the global leaderboard, the scoring formula is decimal-odds-based — a correctly predicted lower-probability outcome earns more points than a correctly predicted higher-probability outcome, on the principle that harder Picks should be rewarded. The conviction multiplier is calculated at the moment a Pick locks (5 minutes before kickoff) and reflects the diversity or unanimity of the Picks you have submitted across the contexts in which you participate. Per-group scoring is configurable by the group creator at the moment of group creation and is locked once the first fixture in a phase begins; details of the available scoring modes are described in our help documentation.

bGuru's prediction engine generates a probability for each market outcome. Those probabilities are statistical estimates, not guarantees. The engine is operated solely for the purpose of providing the Service; the displayed probabilities are not, and must not be treated as, financial, investment, or any other form of professional advice of any kind.

Reputation points and leaderboard positions have no monetary value and cannot be redeemed, transferred, sold, or exchanged for anything of monetary value. They are tied to the Account and are extinguished when the Account is closed.

§8 Premium-tipster bundling

bGuru may from time to time select Picks from active users for inclusion in paid platform tiers ("Premium-Tipster" bundles). Selection is at bGuru's discretion and is based on measurable Pick accuracy, leaderboard position, and Community-Guidelines compliance. Selected users will be notified before any of their Picks are bundled, may opt out at any time through the in-app settings, and remain free to use the Service in the ordinary way.

Selected users receive in-platform benefits, which may include: a Premium-Tipster badge, increased visibility on leaderboards and in discovery surfaces, complimentary access to any paid platform tier for the duration of selection, and additional profile features. No cash compensation is owed to any selected user at MVP launch. Any future cash revenue-share programme will be described in a separate agreement at the time it is offered, and is not part of these Terms. Participation in any future cash programme will be voluntary and will require an additional opt-in.

The optional paid tier is a subscription to a content product. Subscribers receive no advantage in the contest mechanics described in §4 or §7 — no extra Picks, no boosted Conviction Score, no privileged access to outcomes.

§9 Account suspension & termination

bGuru may suspend or terminate your Account, with or without notice, for: breach of these Terms or the Community Guidelines; multi-accounting (see §6); fraud, abuse, or misuse of the Service; a binding request from a competent regulatory authority; or any conduct that materially harms other users or the integrity of the Service. We use a proportionate response ladder — warn, mute, suspend, ban — wherever the circumstances permit, and we will provide a written explanation when we suspend or terminate an Account, except where doing so would interfere with an ongoing investigation or breach a legal obligation.

You may close your Account at any time through the in-app account-deletion flow (see §10).

On termination of your Account (whether by you or by us), your Content stops being publicly visible and is purged in accordance with §10, except (a) aggregated, de-identified statistics that no longer relate to you as an identified or identifiable individual, and (b) any Content lawfully required to be retained for the establishment, exercise, or defence of legal claims or for compliance with a legal obligation.

European Union / EEA (DSA Art. 14 + Art. 20). If you are a user in the EU or EEA, you have the right under Article 20 of Regulation (EU) 2022/2065 (the Digital Services Act, DSA) to challenge any account-suspension, content-removal, or access-restriction decision through bGuru's internal complaint-handling system, accessible via Settings → Help → Contact Us or by writing to legal@bguru.app. We will process all such complaints free of charge and will communicate a reasoned decision within a reasonable period. If you are not satisfied with the outcome of the internal complaints process, you may refer your complaint to a certified out-of-court dispute settlement body under DSA Art. 21 or to the Digital Services Coordinator of your member state of habitual residence. These rights apply in addition to any judicial remedy available under the law of your member state.

§10 Account deletion

You may request deletion of your Account at any time through the in-app account-deletion flow (Settings → Account → Delete account). On submitting a deletion request, your Account is scheduled for permanent deletion after a 30-day grace period, during which you may cancel the request by signing in and selecting "Cancel deletion". After the 30-day grace period expires, your personal data is hard-deleted from active systems and is removed from regular backups in accordance with the backup-rotation schedule (a deletion request is honoured against backup copies as the rotation cycles).

Certain residual data may survive deletion: aggregated, de-identified leaderboard statistics in which your identity has been severed; archived support correspondence required for legal-claims defence under the applicable mandatory law (Art. 17(3) GDPR and equivalent); and ledger entries required to comply with applicable accounting or tax obligations. Where required by mandatory local law, we will identify any such retained data in writing on request.

Requests to exercise statutory deletion rights (see jurisdiction-specific paragraphs below) may be submitted through the in-app flow above or in writing to legal@bguru.app.

United Kingdom (UK GDPR Art. 17 + DPDI Act 2025). UK users have the right to erasure of their personal data under UK GDPR Art. 17 and the Data Protection Act 2018, as carried forward and supplemented by the Data (Use and Access) Act 2025. The 30-day grace period described above is consistent with UK GDPR Art. 17 and Art. 12(3) (which require a controller to act on erasure requests without undue delay and at the latest within one month). The narrow exceptions in Art. 17(3) — including where retention is necessary for the establishment, exercise, or defence of legal claims, or for compliance with a legal obligation — may apply to specific data points (such as aggregated, de-identified leaderboard history where individual identity has been severed), and bGuru will identify any such retained data in writing if you request it. Requests should be directed to legal@bguru.app.

European Union / EEA (GDPR Art. 17). Users in the EU/EEA have the right to request erasure of their personal data under Article 17 of Regulation (EU) 2016/679 (GDPR), commonly known as the right to be forgotten. The 30-day grace period and subsequent hard-deletion process described above are designed to align with that right: submitting an account-deletion request in the bGuru app constitutes an erasure request under GDPR Article 17, and the permanent purge that follows the grace period gives effect to it. Certain categories of data may be retained beyond the grace period where one of the exceptions in GDPR Article 17(3) applies — for example, where data is necessary for the establishment, exercise, or defence of legal claims (Art. 17(3)(e)), or where retention is required to comply with a legal obligation (Art. 17(3)(b)); in those cases bGuru will retain the minimum data necessary for the minimum period required and will inform you of any such retention. You may also submit an erasure request in writing to our EU Art. 27 representative at the contact details in §17.2, or directly to legal@bguru.app pending their appointment, and we will respond within 30 days per GDPR Article 12.

Israel (Privacy Protection Law 5741-1981 Amendment 13 §17 / חוק הגנת הפרטיות, תשמ"א-1981, תיקון 13, §17). Amendment 13 to the Privacy Protection Law (effective August 2025) introduced an explicit right to erasure mirroring GDPR Article 17: a data subject may request deletion of their personal data where the processing is no longer necessary for the purpose for which it was collected, or where the data subject withdraws consent (where consent is the applicable lawful basis). bGuru's 30-day grace period between an account-deletion request and hard deletion of personal data gives users the opportunity to cancel a deletion request made in error (using the in-app cancellation flow); it is designed to be consistent with Amendment 13's requirement that personal data be deleted "without undue delay" once the deletion obligation is triggered. bGuru will acknowledge a statutory deletion request submitted under PPL §17 within 30 days of receipt, per the response-time obligation under Amendment 13. After the 30-day grace period, bGuru permanently deletes all personal data that does not fall within a permitted retention category, as required by §17. Aggregated, de-identified leaderboard statistics that do not relate to an identified or identifiable individual are not personal data and may be retained after deletion; they are severed from any identifier linking them to the deleted account before the hard-delete completes.

§11 Third-party intellectual property

§11.1 Nominative descriptive use — marks displayed in the Service

bGuru displays the names, crests, logos, and related marks of sports teams, clubs, leagues, competitions, national football associations, and continental confederations (together, "Third-Party Marks") for the sole descriptive purpose of identifying the matches, competitions, and contests on which users submit Picks. Examples of Third-Party Marks displayed include: the FIFA World Cup mark and FIFA marks generally; UEFA and UEFA competition marks (Champions League, Europa League, Conference League, EURO); CONMEBOL marks (Copa América); AFC, CAF, OFC, and CONCACAF marks; Premier League, La Liga, Bundesliga, Serie A, Ligue 1, Eredivisie, Primeira Liga, MLS, Brasileirão, J1 League, K League, Liga MX, A-League, Ligat ha'Al, Saudi Pro League, and any other league or competition whose fixtures are made available through the Service; and the crests and names of the clubs and national teams that participate in those competitions. This list is illustrative and non-exhaustive; the definitive set of marks displayed is determined by the sports-data coverage of the Service at any given time.

All Third-Party Marks displayed in the Service are the registered trademarks, unregistered marks, or protected insignia of their respective owners. Their display in the Service does not imply any ownership claim by bGuru, and does not constitute or imply any endorsement of, sponsorship of, or official connection to bGuru by any mark owner.

bGuru's use of Third-Party Marks is descriptive, not source-indicating, and is intended to fall within the following protective doctrines in the jurisdictions in which the Service operates:

• United States — Nominative fair use (New Kids on the Block v. News America Publishing, Inc., 971 F.2d 302 (9th Cir. 1992); Toyota Motor Sales, U.S.A., Inc. v. Tabari, 610 F.3d 546 (9th Cir. 2010)); descriptive use and non-trademark use under Lanham Act § 33(b)(4) (15 U.S.C. § 1115(b)(4)). bGuru does not use Third-Party Marks on goods or services it sells; it uses them only to identify and describe the real-world entities whose match outcomes the Service covers.
• European Union / EEA — Descriptive use of third-party marks permitted under Art. 14(1)(b) of Directive (EU) 2015/2436 (the Trade Mark Directive), as implemented in each member state: marks may be used by any person to indicate the intended purpose of goods or services, or characteristics of goods or services, provided the use is in accordance with honest practices in industrial or commercial matters. bGuru's identification of match participants is a use of marks to indicate purpose and characteristics of the Service.
• United Kingdom — Descriptive use under Trade Marks Act 1994 s. 11(2)(b): a registered mark is not infringed by use of the mark to indicate the kind, quality, intended purpose, or other characteristics of goods or services, provided the use is in accordance with honest practices. bGuru's display of league and club marks to identify the matches covered by the Service is such a use.
• Israel — Descriptive and informatory use under Trademarks Ordinance [New Version] 5732-1972 § 47: use of a trademark in good faith that is descriptive of goods or services, or that indicates the kind, quality, or other characteristics of goods or services, does not constitute infringement provided the use does not imply sponsorship or endorsement. bGuru's use satisfies this standard.
• Australia — Descriptive use exception under Trade Marks Act 1995 (Cth) s. 122(1)(b): a person does not infringe a registered trade mark if they use the mark in good faith to indicate the kind, quality, intended purpose, or other characteristics of goods or services. bGuru's identification of competitions and teams is such a use.
• Japan — Descriptive use consistent with Trademark Act (商標法, Act No. 127 of 1959) Art. 26(1)(ii): registered marks are not infringed by use of marks that indicate the quality, origin, or other characteristics of goods or services, provided the use is not source-indicating.
• South Korea — Descriptive use consistent with Trademark Act (상표법, Act No. 14033) Art. 90(1)(3): registered marks are not infringed by use in good faith to describe the nature, quality, or purpose of goods or services.
• Brazil — Industrial Property Law (Lei No. 9.279/1996) Art. 132(II): a mark owner cannot prohibit the use of the mark to identify goods or services of the same kind, provided the use is in accordance with honest commercial practices.

§11.2 No affiliation with mark owners

bGuru is not affiliated with, endorsed by, sponsored by, licensed by, or otherwise officially connected with any of the following: FIFA; UEFA; CONMEBOL; AFC; CAF; OFC; CONCACAF; the Premier League; La Liga; Bundesliga; Serie A; Ligue 1; Eredivisie; Primeira Liga; MLS; Brasileirão; J1 League; K League; Liga MX; A-League; Ligat ha'Al; Saudi Pro League; the Football Association (FA); RFEF; DFB; FIGC; FFF; KNVB; FPF; IFA; or any other league, club, national football association, continental confederation, broadcaster, or governing body whose marks appear in the Service (together "Third-Party Rights Owners").

The Service is independent third-party software built for sports prediction enthusiasts. No Third-Party Rights Owner has reviewed, approved, or endorsed the Service or any content within it.

§11.3 FIFA World Cup 2026 — specific disclaimer

The Service is not licensed by, endorsed by, or affiliated with FIFA or the FIFA World Cup. bGuru is independent third-party sports-prediction software. The Service uses World Cup fixture information and related sporting data for the descriptive purpose of identifying the matches on which users submit Picks. "FIFA", "FIFA World Cup", "World Cup 2026", the World Cup trophy image, the official mascot, the official tournament logo, and all related marks are the exclusive property of FIFA. bGuru makes no claim to those marks. Any display of World Cup match information in the Service is descriptive of real-world events, not a claim of official affiliation.

§11.4 Data source — sports data feed

Sports data (including fixture metadata, team names, league names, competition names, and team crests and league logos displayed in the Service) is sourced from the API-Football sports data feed operated by API-Sports SAS (France). bGuru is a licensed consumer of that data feed. bGuru does not own, and does not claim to own, any image, logo, crest, or other creative work served through that feed. The underlying intellectual property in those images belongs to the respective Third-Party Rights Owners.

Player profile images, where displayed in the Service, are likewise served via the API-Football media CDN (media.api-sports.io). bGuru does not host or own player photos; it requests them from the CDN as provided. If a player or their authorised representative wishes to request removal of a player photo from the CDN, contact should be directed to API-Sports SAS at the contact details published on their platform.

§11.5 Player names, statistics, and rights of publicity

bGuru ingests, stores, and displays the following categories of player data sourced from its sports data feed: full name; nationality; date of birth; height; position; club affiliation (current and historical); season statistics (goals, assists, appearances, ratings); injury status; and, where provided by the feed and rendered in the Service, profile photo.

This data is used for the descriptive purpose of identifying which players participate in the matches and competitions on which users submit Picks, and for displaying supporting statistical context. bGuru makes no claim that any player endorses, sponsors, or is associated with bGuru.

bGuru's use of player data is intended to fall within the following protective doctrines:

• United States — Factual sports information, including player names and statistical performance, is protected First Amendment speech and does not constitute a violation of the right of publicity where the use does not create a false impression of endorsement and where the primary expressive value is identification of real-world sporting participants rather than commercial exploitation of the player's identity. C.B.C. Distribution and Marketing, Inc. v. Major League Baseball Advanced Media, L.P., 505 F.3d 818 (8th Cir. 2007), cert. denied, 553 U.S. 1090 (2008) (First Amendment protection for use of real player names and statistics in fantasy sports products); Keller v. Electronic Arts, 724 F.3d 1268 (9th Cir. 2013) (transformative-use test); Hart v. Electronic Arts, Inc., 717 F.3d 141 (3d Cir. 2013). bGuru does not model player avatars or likenesses in a video-game context; it uses names and factual statistics to describe real sporting events.
• European Union / EEA — GDPR Art. 85 recognises that processing personal data for journalistic, academic, and expressive purposes is compatible with privacy rights. The display of player names and factual sporting statistics as part of a sports-information service falls within that carve-out as applied by member states through their Art. 85(2) national derogations. German law: the BGH "Caroline of Monaco" line (BGH, 19 December 1995, VI ZR 15/95) distinguishes personality rights from factual reporting of public-figure activities — professional athletes competing in public events have reduced personality-rights protection with respect to their professional conduct and statistics. French law: Code civil Art. 9 protects la vie privée; factual reporting of public sporting activities by professional athletes is recognised as falling within the Loi du 29 juillet 1881 press-freedom framework as applied to sports information services (Cour de cassation, 1re chambre civile, 20 February 2001, Bull. civ. I, No. 44). Italian law: Codice civile Art. 10 and Legge 633/1941 protect portrait rights, but professional athletes are treated as public figures whose public sporting activities may be reported factually without consent.
• United Kingdom — English law does not recognise a general image right or right of publicity distinct from passing off. Passing off protects against a false misrepresentation that a player endorses or is commercially associated with a product (Irvine v. Talksport Ltd [2002] EWHC 367 (Ch)). bGuru's factual, non-endorsement display of player names and statistics does not create a false impression of endorsement and therefore does not engage the passing-off test. There is no statutory image right in the UK.
• Israel — The Right of Publicity Law 5743-1983 (חוק זכות הפרסום, תשמ"ג-1983) protects against commercial exploitation of a person's name, likeness, or other identifying features without consent. The Law contains a recognised exception for factual sports reporting and for informatory use of a person's identity in connection with genuine coverage of their professional activities. bGuru's use — displaying factual match participation data, career statistics, and injury status as sports information — is intended to fall within that exception.
• Australia — No federal right of publicity exists in Australia. State-level personality-rights protection is limited to passing off and the Australian Consumer Law's misleading-conduct provisions (ACL s. 18); bGuru's factual, non-endorsement display of player data does not engage either. Henderson v. Radio Corp Pty Ltd (1969) 87 WN (Pt 1) (NSW) 172 established that use of a public figure's name in a factual, non-endorsement context does not constitute passing off.

§11.6 No implied endorsement by players

bGuru does not claim or imply that any player whose name, statistics, or (where displayed) photograph appears in the Service has endorsed, sponsored, participated in, or has any commercial relationship with bGuru. Players' names, images, and statistics are used solely for the factual identification of who participates in a given match or competition.

§11.7 User content and third-party marks

Users may not post, upload, or share Content that uses Third-Party Marks in a manner that: (a) falsely suggests that any Third-Party Rights Owner has endorsed, approved, sponsored, or is affiliated with bGuru; (b) falsely suggests that the user is an official representative, employee, or agent of any Third-Party Rights Owner or any player; or (c) amounts to trademark infringement, passing off, or the making of a false commercial connection between bGuru and any Third-Party Rights Owner. Examples of prohibited conduct include using a club crest as your bGuru avatar in a way that implies you are posting on behalf of that club as an official spokesperson, or styling your group as an official club-operated group when it is not. bGuru will process valid trademark-infringement notices received at legal@bguru.app.

§12 Disclaimers

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK AND RESPONSIBILITY.

bGuru's prediction probabilities are statistical estimates generated by an in-house mathematical model, not guarantees of any outcome. They must not be used as, and you must not rely on them as: financial advice, investment advice, sports-betting or gambling advice, or any other form of professional or consequential advice. Decisions you make based on bGuru's content — including, without limitation, any betting, financial, business, or personal decision — are made at your sole discretion and risk; bGuru is not responsible for any loss, damage, or other consequence resulting from such reliance.

bGuru is currently operated as an independent solo-developer project from Israel. It is not a regulated financial-services provider, a licensed sportsbook, a fantasy-sports operator, or a betting operator of any kind. Nothing in the Service is intended to facilitate, encourage, or constitute any of those activities; if you are looking for any of those services, the Service is not for you.

To the maximum extent permitted by mandatory law, bGuru disclaims all implied warranties and representations not expressly stated in these Terms, including any implied warranty of merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, or uninterrupted availability.

We do not guarantee that the Service will be available without interruption, that any specific match, league, or competition will be covered at any time, or that the data we display (for example, fixture metadata, lineups, statistics, scoreline updates) is free of errors. We rely on third-party sports-data feeds; while we apply reasonable quality controls, we cannot warrant the accuracy or timeliness of any such feed, and you should not rely on any sports data shown in bGuru as a substitute for an authoritative source.

This §12 does not affect the statutory rights that apply to consumers under mandatory local law — see §13.2. Where a court of competent jurisdiction holds that any disclaimer in this §12 is unenforceable in your jurisdiction, the disclaimer is severed and the remaining provisions of these Terms continue in full effect.

§13 Limitation of liability

§13.1 Cap

To the maximum extent permitted by mandatory law, bGuru's total aggregate liability to you arising out of or relating to these Terms or your use of the Service is limited to the greater of (a) the fees you paid to bGuru in the 12 months preceding the event giving rise to the liability, or (b) USD 50. For free-tier users (the default), this cap is USD 50. bGuru is not liable for indirect, incidental, special, consequential, exemplary, or punitive damages, including without limitation loss of profit, loss of business opportunity, loss of reputation, or loss of data, regardless of the legal theory on which the claim is brought.

§13.2 Statutory carve-outs

Nothing in §13.1 (the liability cap) limits any right or remedy that mandatory law in your jurisdiction prohibits parties from contractually excluding or limiting. The following non-exhaustive paragraphs describe the principal carve-outs by jurisdiction.

United States (state anti-exculpation rules + UDAP statutes). Nothing in §13.1 limits or excludes bGuru's liability to US users for: (a) death or personal injury caused by bGuru's gross negligence or intentional misconduct; (b) fraud or fraudulent misrepresentation; (c) liability that cannot lawfully be limited or excluded under applicable US federal or state law, including without limitation California Civil Code § 1668 (which voids contractual exculpation for wilful wrongdoing or violation of law), Florida Statutes § 725.06, and equivalent anti-exculpation provisions of other states; (d) statutory remedies available to consumers under state unfair, deceptive, or abusive acts or practices statutes ("UDAP"), including the California Consumer Legal Remedies Act (Cal. Civ. Code §§ 1750–1784), the California Unfair Competition Law (Cal. Bus. & Prof. Code §§ 17200–17210), and New York General Business Law §§ 349–350, none of which may be waived by contract — and specifically including the right to seek public injunctive relief under the UCL and CLRA (which cannot be waived in any forum per McGill v. Citibank, N.A., 2 Cal. 5th 945 (2017), Cal. Civ. Code § 3513), as also expressly preserved in §15.2.10; (e) data-breach notification rights and statutory damages available to California residents under the California Consumer Privacy Act, Cal. Civ. Code § 1798.150, in the event of unauthorised access to unencrypted personal information resulting from bGuru's failure to implement reasonable security; and (f) any other liability that applicable law in the user's state of residence expressly prohibits parties from contractually excluding or capping.

United Kingdom (Consumer Rights Act 2015 Pt 1 Ch 3 + Pt 2 ss. 62–76, Unfair Contract Terms Act 1977 s. 2(1), common law fraud). Nothing in §13.1 limits or purports to limit bGuru's liability for: (a) death or personal injury caused by bGuru's negligence (per the Unfair Contract Terms Act 1977 s. 2(1), which renders any such limitation void); (b) fraud or fraudulent misrepresentation; (c) breach of the implied terms as to quality and fitness for purpose in respect of digital content under Consumer Rights Act 2015 Pt 1 Ch 3 (ss. 34–36) — specifically, the implied term that digital content is of satisfactory quality and the remedies of repair, replacement, or price reduction that flow from breach; or (d) any other liability that cannot be lawfully excluded or limited under the law of England and Wales, Scotland, or Northern Ireland.

European Union / EEA (Unfair Contract Terms Directive 93/13 + per-member-state civil codes). Nothing in §13.1 limits or excludes bGuru's liability for: (a) death or personal injury caused by bGuru's negligence; (b) intentional misconduct (Vorsatz) or gross negligence (grobe Fahrlässigkeit) — note that member-state formulations vary: German law (BGB §309 No. 7) prohibits limitation for gross negligence causing personal injury or property damage; French law (Code civil Art. 1170, as interpreted following the ordonnance of 10 February 2016) prohibits clauses that deprive an essential obligation of its substance; Italian law (Codice Civile Art. 1229) prohibits any advance exclusion of liability for intentional acts or gross negligence; and equivalent provisions apply in other member states; and (c) any other liability that cannot lawfully be excluded or limited under the mandatory consumer-protection provisions of the law of the member state in which you are habitually resident, including rights conferred by Council Directive 93/13/EEC on unfair terms in consumer contracts and by Directive 2011/83/EU on consumer rights, to the extent those rights cannot be derogated from by agreement. Annex 1(q) of Directive 93/13/EEC specifically identifies as potentially unfair any term having the object or effect of excluding or hindering consumers' rights to take legal action, and we interpret §13.1 consistently with that principle. For the avoidance of doubt, where the USD 50 cap in §13.1 would, in the circumstances of a particular claim by an EU/EEA consumer, operate to limit bGuru's liability below the consumer's actual proven loss in a manner that is "significantly imbalanced" within the meaning of Directive 93/13/EEC Art. 3(1), that cap does not apply to that consumer's claim and the consumer retains the right to full recovery under the applicable mandatory law of their member state of habitual residence.

Israel (Standard Contract Terms Law 5742-1982 §§3–4 / חוק החוזים האחידים, תשמ"ב-1982 §§3, 4 + Consumer Protection Law 5741-1981 §4A / חוק הגנת הצרכן, תשמ"א-1981 §4A + Torts Ordinance (New Version) 5728-1968 / פקודת הנזיקין (נוסח חדש), תשכ"ח-1968). Nothing in §13.1 limits or excludes bGuru's liability for: (a) death or personal injury caused by bGuru's negligence, per the Torts Ordinance; (b) loss or damage caused by bGuru's intentional act (מעשה מכוון) or gross negligence (רשלנות רבתי); (c) fraud or fraudulent misrepresentation; or (d) any liability that cannot lawfully be limited or excluded under the Standard Contract Terms Law 5742-1982 — in particular, §3 of that Law deems void any standard-contract term that deprives a consumer of a right conferred by law, causes a fundamental imbalance in the parties' rights, or is manifestly unfair in the circumstances, and §4 preserves a consumer's right to enforce their mandatory statutory remedies notwithstanding a contractual limitation. Consumer remedies mandated by the Consumer Protection Law 5741-1981 §4A (required disclosures and the consumer's right to rescind where mandatory information was not provided) are similarly unaffected by §13.1. For the avoidance of doubt: where an Israeli court determines that the USD 50 aggregate cap in §13.1 is, as applied to the specific circumstances of an Israeli-resident consumer's claim, a "discriminating term" (תנאי מפלה) or manifestly disadvantageous term under Standard Contract Terms Law 5742-1982 §3(5), that cap does not apply to that consumer's claim, and bGuru's liability is determined by the applicable provisions of Israeli mandatory law without the contractual ceiling.

Rest of world (BR / AU / CA-QC / KR / JP / ZA / IN). Nothing in §13.1 limits bGuru's liability to users in the following jurisdictions to the extent that applicable mandatory law prohibits such limitation: (a) in Brazil, nothing limits liability to the extent the limitation would constitute an "abusive clause" within the meaning of the Consumer Defense Code (CDC, Law No. 8.078/1990) Art. 51, and in particular liability for damage caused to Brazilian consumers by defective service provision cannot be excluded or capped below the limits set by CDC Arts. 14 and 20; (b) in Australia, nothing limits any guarantee, remedy, right, or obligation conferred by the Australian Consumer Law (Schedule 2 to the Competition and Consumer Act 2010) that cannot lawfully be excluded or limited, including the non-excludable guarantees relating to the supply of services under ACL ss. 60–62; (c) in Quebec, nothing limits liability to the extent prohibited by the Civil Code of Québec Art. 1474, which renders void any clause exempting a party from liability for bodily injury, or for material damage caused intentionally or through gross fault; (d) in South Korea, nothing limits liability to the extent that such limitation is rendered void under the Act on the Regulation of Terms and Conditions (약관의 규제에 관한 법률) or the Consumer Protection in Electronic Commerce Act (전자상거래 등에서의 소비자보호에 관한 법률); (e) in Japan, nothing limits liability to the extent that such limitation is rendered void by the Consumer Contract Act (消費者契約法, Law No. 61 of 2000) Arts. 8 through 10, including — without limitation — any clause that wholly exempts bGuru from liability for damage caused to a Japanese consumer by bGuru's intentional or grossly negligent acts; (f) in South Africa, nothing limits liability to the extent prohibited by the Consumer Protection Act 68 of 2008 §51, and in particular liability for death or injury resulting from bGuru's gross negligence or wilful conduct cannot be excluded; and (g) in India, nothing limits liability to the extent prohibited by the Consumer Protection Act 2019 or applicable mandatory rules issued thereunder. In addition, nothing in §13.1 limits bGuru's liability to any user for: (i) death or personal injury caused by bGuru's negligence; (ii) fraud or fraudulent misrepresentation; or (iii) any other matter for which limitation of liability is prohibited as a matter of mandatory law in the jurisdiction of that user's habitual residence.

§14 Geographic restrictions

§14.1 Introduction

bGuru is a global service, but it is not available in every country or territory. We have made the decision — in some cases because we are legally required to, in other cases as a precautionary measure — to prevent access to the Service from certain jurisdictions.

If you are located in a jurisdiction listed in §14.2, you may not register for, access, or use bGuru. This restriction applies regardless of how you access the Service. Specifically, accessing bGuru from a restricted jurisdiction by using a virtual private network (VPN), proxy server, Tor relay, or any other technical means of circumventing geographic controls is a breach of these Terms. Where we detect or have reasonable grounds to believe such circumvention is occurring, we may immediately suspend or permanently terminate the relevant account and forfeit that account's leaderboard standing without prior notice or compensation of any kind.

The geo-restrictions in §14.2 are maintained for the following reasons, which apply separately and in combination:

Sanctions compliance. Several jurisdictions or regions are subject to comprehensive international economic sanctions — including those imposed by the United States Office of Foreign Assets Control (OFAC), the European Union, and the United Kingdom Office of Financial Sanctions Implementation (OFSI). Providing the Service in sanctioned jurisdictions or to persons designated on the OFAC Specially Designated Nationals list or equivalent EU/UK designation lists would expose bGuru to legal liability regardless of the nature of the Service.

Morality and content regulation. Certain jurisdictions apply content-blocking frameworks that are incompatible with bGuru's content posture, regardless of whether bGuru's activity is lawful on a substantive analysis. Where the risk of broad administrative blocking of the Service — affecting all of our users in a jurisdiction — is high, we pre-emptively restrict access rather than risk disrupted service or enforcement risk.

Data-localisation infeasibility. Certain jurisdictions require that personal data relating to their residents be stored and processed exclusively within their borders, or impose data-export controls that bGuru's current infrastructure cannot satisfy at its current scale. We restrict access from those jurisdictions rather than operate in non-compliance.

We review this list at least annually. Where a jurisdiction's posture changes materially, we will update this section and notify active users affected by any new restriction.

§14.2 Restricted jurisdictions

Sanctions — OFAC, EU, and UK OFSI aligned

The following jurisdictions are geo-blocked because they are subject to comprehensive international economic sanctions under one or more of: OFAC's country-based sanctions programs, the EU's Common Foreign and Security Policy restrictive measures, and UK OFSI's financial sanctions regimes. In each case, sanctions compliance is the controlling reason; the substantive legality of bGuru's activity in those jurisdictions is irrelevant to this decision.

• Russia — blocked under comprehensive OFAC/EU/UK sanctions (including US Executive Order 14071 and subsequent designations; EU Regulation 833/2014 as amended).
• Iran — blocked under comprehensive OFAC sanctions.
• North Korea — blocked under comprehensive OFAC sanctions and UN Security Council designations.
• Cuba — blocked under comprehensive OFAC sanctions.
• Syria — blocked under comprehensive OFAC sanctions and EU restrictive measures.
• Belarus — blocked under OFAC and EU sectoral sanctions.
• Sanctioned regions of Ukraine — the following regions are blocked under OFAC/EU/UK sanctions that remain in effect at the date of these Terms: Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia. This geo-block applies to access originating from within those regions; it does not restrict access by Ukrainian citizens outside those regions.

We do not accept registrations from, and we do not knowingly permit use of the Service by, individuals or entities designated on any OFAC SDN list, EU consolidated sanctions list, or UK OFSI consolidated list, regardless of their location. bGuru employs geo-IP blocking and reasonable technical controls to detect and prevent access from sanctioned jurisdictions; we maintain and periodically update those controls and, where applicable, will incorporate SDN-list screening into any payment-processing flow activated in connection with a paid tier.

Morality and content regulation

• Turkey (Türkiye) — blocked as a precautionary measure. The Information and Communication Technologies Authority (BTK), acting under Law No. 5651 and its amendment Law No. 7253, maintains an extensive content-blocking regime. In 2024 and 2025, BTK blocked large numbers of websites and apps associated with prediction and sports-adjacent content on "protection of public order and public morals" grounds, without advance notice or challenge opportunity. The legal test applied by BTK does not align with bGuru's non-gambling characterisation in any other jurisdiction, and the administrative risk of broad IP-level blocking affecting all Turkish users without recourse justifies pre-emptive restriction. We will review this classification annually and will reverse it if the regulatory posture materially improves.

Data-localisation infeasibility

• Mainland China (People's Republic of China) — blocked. China's Personal Information Protection Law (PIPL, effective Nov 2021), Data Security Law (DSL, effective Sep 2021), and Cybersecurity Law (CSL, effective Jun 2017) collectively impose data-localisation requirements and cross-border transfer restrictions that bGuru cannot satisfy at its current scale. The App Store's China-specific compliance regime also involves separate regulatory approvals that bGuru has not sought.
• Hong Kong SAR — blocked. In addition to data-protection regulatory uncertainty following the application of the National Security Law (2020), Hong Kong's regulatory environment has shifted materially toward mainland China's posture. We have taken a precautionary approach.
• Macau SAR — blocked. Macau's data-protection regime and its specific online-content regulatory posture create compliance complexity incompatible with bGuru's current infrastructure.

Compliance infrastructure pending — v1.1 launch markets

The following jurisdictions are not regulatorily prohibited from accessing bGuru; they are unavailable at this version of the Service while specific compliance infrastructure is built. Each will be opened in a future version once the relevant infrastructure is in place. No geo-block bypass via VPN or proxy is permitted while a jurisdiction is in this list, on the same terms as §14.1.

• Brazil — not available at this version. The Digital Statute of the Child and Adolescent (Estatuto Digital, Law No. 15.211/2025) requires verifiable parental consent for users under 18, which exceeds bGuru's 16+ baseline under §3. Brazil will be opened once a verifiable-parental-consent provider is integrated.
• India — not available at this version. The Digital Personal Data Protection Act 2023 requires verifiable parental consent for users under 18, which exceeds bGuru's 16+ baseline under §3. India will be opened once a verifiable-parental-consent provider is integrated.
• Canada (including Quebec) — not available at this version. The Quebec Charter of the French Language (Bill 96) requires consumer contracts directed at Quebec residents to be made available in French; Canada-wide App Store country availability cannot be enabled at MVP without French-language translations of all four legal documents. Canada (including Quebec) will be opened once the French-language translation track is delivered.
• France — not available at this version. The Loi Toubon (Law No. 94-665) requires consumer contracts in French. France will be opened together with Canada once the French-language translation track is delivered.
• Belgium — not available at this version. The Code of Economic Law Book VI requires consumer contracts directed at Belgian residents in the relevant language for the user's region (French for Wallonia, Dutch/Flemish for Flanders, German for the German-speaking Community). Belgium will be opened together with France and Canada once the French + Dutch/Flemish + German translation tracks are delivered.

§15 Governing law & dispute resolution

§15.1 Governing law and primary forum

These Terms are governed by the laws of the State of Israel, without regard to its conflict-of-law rules.

Any dispute, claim, or controversy arising out of or relating to these Terms or the Service that is not resolved by the consumer carve-outs in §§15.2–15.5 shall be subject to the exclusive jurisdiction of the Tel Aviv–Yafo District Court (and, for claims within the monetary threshold of the Magistrate's Court, the Magistrate's Court sitting in Tel Aviv–Yafo).

Notwithstanding the exclusive-jurisdiction clause above, Israeli-resident consumers retain the right to bring proceedings in any Israeli court of competent jurisdiction in their district of residence, as preserved by Standard Contract Terms Law 5742-1982 §4 (חוק החוזים האחידים, תשמ"ב-1982 §4). The Tel Aviv–Yafo forum designation applies to business-to-business disputes and to bGuru's own enforcement claims; it does not prevent an Israeli consumer from suing bGuru in the court nearest to their residence.

Why Israeli law and Israeli courts? bGuru is operated from Israel. Israeli law is your friend here, not an inconvenience: the Standard Contract Terms Law 5742-1982 / חוק החוזים האחידים, תשמ"ב-1982 §4 provides that a forum-selection clause that deprives a consumer of the right to litigate in their own jurisdiction is a "discriminating term" and presumptively unenforceable. By selecting Israeli courts — the courts of the operator's own domicile — this clause does not impose a foreign or distant forum on any Israeli-resident consumer. Israeli-resident users retain the full rights afforded by Israeli consumer law in their local Israeli courts. Non-Israeli consumers retain the carve-outs expressly granted in §§15.2–15.5.

The §§15.2–15.5 carve-outs prevail for consumers in those regions. Nothing in this §15.1 overrides or limits the consumer-protection rights of any user who is:

• a consumer resident in the European Union or EEA (§15.3 applies; Rome I Regulation Art. 6 and Brussels I bis Regulation Arts. 17–19 preserve mandatory local law and home-court access);
• a consumer resident in the United Kingdom (§15.4 applies; Consumer Rights Act 2015 §62 unfair-terms regime and UK procedural rules are preserved);
• a user located in the United States (§15.2 applies; arbitration and US consumer protections govern); or
• a consumer in any other jurisdiction whose mandatory law grants home-court access or governing-law protection (§15.5 applies).

Where an Israeli court applies this §15.1 to a dispute involving a consumer resident outside Israel, it shall in all cases give effect to the mandatory consumer-protection provisions of the consumer's local law to the extent required by Israeli private international law and to the extent the §§15.3–15.5 carve-outs apply.

§15.2 United States — arbitration and class-action waiver

If you are a user located in the United States, this section applies to you and supersedes any contrary provision in §15.1 regarding the resolution of disputes.

§15.2.1 Agreement to arbitrate

Any dispute, claim, or controversy arising out of or relating to these Terms or your use of the Service ("Dispute") — including questions about the existence, scope, or validity of this arbitration agreement — will be resolved exclusively through final and binding individual arbitration, not in court, except as stated in §15.2.6 (small-claims carve-out) and §15.2.7 (IP injunctions). This agreement to arbitrate is governed by the Federal Arbitration Act, 9 U.S.C. §§ 1–16, and will be interpreted broadly.

§15.2.2 Informal resolution first (mandatory pre-arbitration step)

Before either party initiates arbitration, the claimant must send a written notice of the Dispute ("Notice of Dispute") to the other party — for claims against bGuru, send to legal@bguru.app with the subject line "Notice of Dispute". The Notice must describe the nature of the Dispute, the specific relief sought, and the contact information of the person raising it. The parties then have 30 days from the date the Notice is received to attempt informal resolution in good faith. Neither party may initiate arbitration before this 30-day period expires, unless exigent circumstances exist (such as imminent expiration of a statute of limitations). Any statute of limitations is tolled during this 30-day informal-resolution period.

§15.2.3 Arbitration administrator and rules

If the Dispute is not resolved informally, it will be submitted to arbitration administered by the American Arbitration Association ("AAA") under the AAA Consumer Arbitration Rules in effect at the time the arbitration is filed (available at www.adr.org), as supplemented by this §15.2. A single neutral arbitrator will be appointed pursuant to those rules. The arbitration may be conducted via written submissions, video conference, or telephone unless the arbitrator determines that an in-person hearing is warranted; in that case, the hearing will be held in the county of your principal residence in the United States, or as otherwise agreed by the parties.

The arbitrator has exclusive authority to resolve any Dispute, including threshold questions of arbitrability, except as provided in §15.2.4 with respect to class-action or mass-arbitration gateway questions.

Costs: bGuru will pay all AAA filing, administrative, and arbitrator fees for any Dispute where your claim is $10,000 or less, unless the arbitrator determines your claim is frivolous or was brought for an improper purpose. For claims above $10,000, the AAA fee schedule applies. If you prevail in arbitration on a claim arising under a state statute that permits recovery of attorney fees, the arbitrator may award you attorney fees under California Code of Civil Procedure § 1284.3 and equivalent statutes in other states; bGuru does not waive any such statutory entitlement.

§15.2.4 Class-action and class-arbitration waiver

To the maximum extent permitted by applicable law, you and bGuru each agree to bring Disputes only in an individual capacity and not as a plaintiff or class member in any purported class action, class-wide arbitration, private-attorney-general action, or other representative proceeding. The arbitrator may not consolidate more than one person's claims and may not preside over any form of a class or representative proceeding. Notwithstanding the foregoing, nothing in this §15.2.4 waives any claim under the California Labor Code Private Attorneys General Act (Cal. Lab. Code § 2698 et seq.) to the extent that such a waiver is unenforceable as a matter of California law.

This class-action waiver is an essential element of the arbitration agreement. If a court of competent jurisdiction determines that the class-action waiver is unenforceable as to any particular claim, then that particular claim must proceed in court, and the parties agree that litigation of that claim will be stayed pending the resolution of any arbitrable individual claims.

§15.2.5 Mass-arbitration batching procedure

The parties acknowledge the risk that a large number of similar claims filed against bGuru simultaneously (a "Mass Arbitration") could impose disproportionate costs on the parties and the AAA. To manage this risk:

(a) Threshold. If 25 or more Disputes are filed within any rolling 90-day period that raise substantially similar factual allegations and seek substantially similar relief ("Coordinated Claims"), the batching procedure in this §15.2.5 applies.

(b) Bellwether selection. The parties will cooperate to select 10 Coordinated Claims to proceed as bellwether arbitrations (five chosen by the claimants' counsel and five chosen by bGuru). Each bellwether arbitration proceeds to a final award before the remaining Coordinated Claims may proceed.

(c) Sequential resolution. After the first 10 bellwether awards are rendered, the parties must participate in a 60-day global mediation session before the AAA or JAMS to attempt resolution of all remaining Coordinated Claims in light of the bellwether results. If mediation fails, the remaining claims proceed in subsequent sequential batches of 10, applying the same bellwether-then-mediate structure.

(d) Stay. All Coordinated Claims not in the current active batch are stayed pending completion of the batch in progress.

(e) Rationale. This procedure tracks the structure of the AAA Supplementary Rules for Mass Arbitration (MA-1 et seq.) and is intended to ensure individual merits review without either side being able to weaponise filing fees or volume against the other.

§15.2.6 Small-claims carve-out; California small-claims option

Either party may pursue an individual Dispute in a small-claims court of competent jurisdiction (federal, state, or local) if the Dispute falls within that court's jurisdictional limits and is brought on an individual, non-class basis. If a Dispute is filed in small-claims court and later removed or transferred to a court of general jurisdiction, either party may elect to compel arbitration under this §15.2.

California users: If you are a resident of California, you may also elect, at your sole option, to litigate any Dispute in the California small-claims court for the county of your residence regardless of the general arbitration agreement above, and bGuru consents to personal jurisdiction in that venue for such individual claims.

§15.2.7 Carve-out for intellectual-property claims and injunctive relief

Notwithstanding the foregoing, either party may seek provisional injunctive or equitable relief (including temporary restraining orders) in a court of competent jurisdiction to prevent irreparable harm pending arbitration. bGuru may pursue claims for infringement of its intellectual-property rights — including copyright, trademark, patent, and trade-secret claims — directly in a court of competent jurisdiction without first arbitrating or complying with the informal-resolution step.

§15.2.8 Opt-out right

You may opt out of this arbitration agreement within 30 days of the date you first agree to these Terms by sending a written opt-out notice to legal@bguru.app with the subject line "Arbitration Opt-Out". Your notice must state your name, the email address associated with your bGuru account, and a clear statement that you wish to opt out of the arbitration agreement. If you opt out, neither party will be bound by the arbitration agreement or the class-action waiver in §15.2.4 with respect to your account, and any Disputes will be resolved in accordance with §15.1. Opting out of arbitration does not affect any other provision of these Terms.

§15.2.9 Severability

If any part of this §15.2 is found to be unenforceable, the remaining parts will continue in full force and effect, except that: if the class-action waiver in §15.2.4 is found unenforceable as to a particular claim, that claim must proceed in court rather than in arbitration, as stated in §15.2.4.

§15.2.10 State UDAP statutes — non-waiver

Nothing in this §15.2 limits or waives any rights you have under applicable state unfair, deceptive, or abusive acts or practices statutes ("UDAP"), including rights conferred by the California Consumer Legal Remedies Act (Cal. Civ. Code §§ 1750–1784), the California Unfair Competition Law (Cal. Bus. & Prof. Code §§ 17200–17210), the New York General Business Law §§ 349–350, and equivalent statutes in other states. Remedies available under UDAP statutes, including statutory damages, public injunctive relief, and attorney-fee awards, are not waived by this agreement.

§15.3 European Union / EEA — consumer carve-out

The governing-law and forum provisions in §15.1 — Israeli law, Tel Aviv courts — are chosen for operational clarity and apply to disputes between bGuru and business users. They do not diminish the mandatory protections that EU and EEA consumer law grants you.

If you are a consumer habitually resident in a member state of the European Union or the European Economic Area, the mandatory consumer-protection provisions of the law of your member state of habitual residence continue to apply to your relationship with bGuru, regardless of the Israeli choice-of-law clause. This follows from Article 6 of Regulation (EC) No 593/2008 (Rome I), which provides that a choice of law cannot deprive a consumer of protections afforded by provisions that cannot be derogated from by agreement under the law of the country where the consumer is habitually resident.

In addition, under Articles 17 to 19 of Regulation (EU) No 1215/2012 (Brussels I bis), you as an EU/EEA consumer may bring proceedings against bGuru in the courts of your own member state, and may only be sued in those same courts. The forum-selection clause in §15.1 does not override or limit that right. Nothing in these Terms excludes, restricts, or modifies any right or remedy conferred on you by the consumer-protection laws of your member state that cannot lawfully be excluded.

§15.4 United Kingdom — consumer carve-out

Nothing in §15.1 (Israeli governing law and Tel Aviv forum) removes any right you have as a consumer under the law of England and Wales, Scotland, or Northern Ireland. Where you are a consumer habitually resident in the United Kingdom, the following applies.

Mandatory consumer protections preserved. The Consumer Rights Act 2015 ("CRA 2015") and any other mandatory consumer-protection provisions of UK law continue to apply to your use of the Service, notwithstanding the choice of Israeli law in §15.1. In particular, the fairness test in CRA 2015 Pt 2 §62 — which renders unenforceable any term causing significant imbalance in the parties' rights and obligations to your detriment — is not displaced by these Terms. Any term that would otherwise be assessed as unfair under §62 will not be enforced against you.

Right to bring proceedings in UK courts. You may bring proceedings in the courts of England and Wales, Scotland, or Northern Ireland (as applicable to your place of residence). This right is preserved by the retained version of Rome I Regulation (Regulation (EC) 593/2008) Art. 6, which prevents a choice-of-law clause from depriving a consumer of the protections afforded by the mandatory rules of their habitual residence. The Tel Aviv forum selection in §15.1 does not prevent you from suing bGuru in your local UK court.

Crown Dependencies (Gibraltar, Isle of Man, Jersey, Guernsey). Users habitually resident in a Crown Dependency retain equivalent rights under the applicable data-protection and consumer-protection legislation of their territory (the Data Protection Act 2018 (Isle of Man), the Data Protection (Jersey) Law 2018, the Data Protection (Bailiwick of Guernsey) Law 2017, and the Gibraltar Data Protection Act 2004 as supplemented by UK GDPR applied under the Withdrawal Agreement) and may bring proceedings in the courts of their territory. The Tel Aviv forum selection in §15.1 does not limit that right.

Plain-language summary. If you are a UK consumer, Israeli law and Tel Aviv courts are where we prefer disputes to be resolved, but they cannot take away the protections you have under UK consumer law. You keep all statutory rights, including the right to go to a UK court.

§15.5 Other jurisdictions — consumer carve-outs

The choice-of-Israeli-law and Tel Aviv forum provisions in §15.1 do not, and are not intended to, deprive any consumer of the mandatory protections to which they are entitled under the law of their habitual residence. The following jurisdictions have specific consumer-protection frameworks that operate as overrides regardless of any choice-of-law or forum-selection clause in these Terms:

Quebec, Canada. By operation of the Civil Code of Québec Art. 3149, a Quebec consumer may always bring proceedings before a Quebec court and may not be required to submit to a foreign forum. The Quebec Consumer Protection Act (LPCQ) establishes rights that cannot be waived by contract, including the right to rescind contracts for services in certain circumstances. Quebec's Charter of the French Language (as amended by Bill 96, 2022) requires that consumer contracts be made available in French before being presented to Quebec consumers. bGuru is committed to making a French-language version of these Terms available to Quebec users prior to or upon launch in Quebec. Until a French-language version is live, bGuru will not present these Terms to Quebec-resident consumers as the operative binding instrument; Quebec-resident users who create an Account before the French-language version is published will be asked to re-confirm acceptance in French upon its publication. If you require a French-language copy in the interim, please contact us at legal@bguru.app and we will provide one within 10 business days.

Brazil. The Brazilian Consumer Defense Code (CDC, Law No. 8.078/1990) Art. 51 provides that contractual clauses that unreasonably disadvantage Brazilian consumers, prevent or impede the exercise of rights, or create disproportionate obligations are void as abusive. Brazilian courts apply the CDC mandatorily to consumer relationships, regardless of any governing-law clause. Per Art. 101 of the Brazilian Code of Civil Procedure (CPC), a Brazilian consumer may bring proceedings before a court of the consumer's domicile. Nothing in §15.1 is intended to limit, and shall not be construed as limiting, the rights guaranteed to Brazilian consumers by the CDC.

Australia. The Australian Consumer Law (ACL, Schedule 2 to the Competition and Consumer Act 2010) confers on Australian consumers non-excludable guarantees and remedies that cannot be contracted out of. To the extent permitted by law, bGuru's maximum liability to Australian consumers for a failure of a guarantee that is not a major failure is limited to supplying the service again or paying the cost of having the service supplied again. Australian consumers may bring claims before the Federal Court of Australia or a relevant state or territory Magistrates Court under the ACL, regardless of §15.1. Nothing in §13.1 excludes, restricts, or modifies any right or remedy, or any guarantee, condition, warranty, or other obligation, conferred on Australian consumers by the ACL.

South Korea. The Act on the Regulation of Terms and Conditions (약관의 규제에 관한 법률, Act No. 3675) renders clauses that are unfair to consumers, or that unreasonably restrict consumer rights, void under Korean law. The Consumer Protection in Electronic Commerce Act (전자상거래 등에서의 소비자보호에 관한 법률) confers additional consumer remedies for disputes arising from electronic services. Korean consumers may bring proceedings before Korean consumer-protection authorities or courts regardless of §15.1.

Japan. The Consumer Contract Act (消費者契約法, Law No. 61 of 2000) Arts. 8 through 10 render void any clause that wholly or substantially exempts a business operator from liability for damage caused to a consumer, or that grants the business operator a unilateral right to determine the contents of a contract in a manner that substantially disadvantages the consumer. Pursuant to the Consumer Contract Act Art. 11-2, choice-of-law provisions in consumer contracts cannot deprive a Japanese consumer of the mandatory protections of Japanese consumer law applicable to their habitual residence.

South Africa. The Consumer Protection Act 68 of 2008 (CPA) §51 prohibits certain categories of contract terms against South African consumers, including clauses that waive liability for gross negligence, that purport to prevent a consumer from exercising a right, or that impose an unreasonable penalty. South African consumers retain all CPA-mandated remedies regardless of §15.1.

Other jurisdictions. Without limiting the foregoing, where you are a consumer resident in: New Zealand (Consumer Guarantees Act 1993, Fair Trading Act 1986), Singapore (Consumer Protection (Fair Trading) Act, Cap. 52A), India (Consumer Protection Act 2019), Mexico (Ley Federal de Protección al Consumidor — LFPC), Argentina (Ley de Defensa del Consumidor No. 24.240), Chile (Ley No. 19.496 de Protección de los Derechos de los Consumidores), Peru (Código de Protección y Defensa del Consumidor — Ley No. 29.571), Colombia (Ley 1480 de 2011 — Estatuto del Consumidor), or the UAE (Federal Law No. 15 of 2020 on Consumer Protection, and where applicable the DIFC Law No. 2 of 2019 or the ADGM Consumer Protection Regulations), you retain all mandatory consumer rights conferred by those laws. The choice-of-law and forum provisions in §15.1 operate only to the extent they are not superseded by mandatory rules of the law of your habitual residence.

§16 Changes to these terms

We may change these Terms from time to time. For material changes — changes that meaningfully affect your rights or obligations under these Terms — we will give you at least 30 days' notice before the change takes effect, by an in-app banner shown the next time you sign in and (where you have provided an email address) by email. For non-material changes (typographical corrections, clarifications, references to new help-doc pages), we may publish an updated version without 30 days' notice; the updated effective date in the document header is the controlling indicator.

For changes required by mandatory law or by a genuine security or safety obligation that cannot reasonably be delayed — and only in those circumstances — we may make the change effective immediately and notify you as soon as practicable thereafter (and in all cases within 7 days). This carve-out is limited to genuinely urgent situations and does not apply to commercially motivated changes that could have been included in a standard 30-day material-change notice.

If you continue to use the Service after the effective date of a change, you are bound by the updated Terms. If you do not agree to a change, your remedy is to stop using the Service and to delete your Account under §10.

EU/EEA users (DSA Art. 12). If you are a user in the EU or EEA, you have the right, during the 30-day notice period for any material change to these Terms, to terminate your use of the Service and to delete your Account under §10 free of any penalty. We will remind you of this right in any material-change notification.

§17 Contact

§17.1 Controller identity

The controller of personal data processed through the Service is:

bGuru (operating as a sole-proprietorship project of an Israeli resident) Web: bguru.app Jurisdiction: Israel

Formal entity formation (Israeli Ltd. or Estonian OÜ) is pending post-MVP review. Until then, bGuru operates as a sole-proprietorship project of an Israeli resident, with legal@bguru.app as the primary contact channel for all data-controller correspondence. This section will be updated via the standard §16 30-day material-change notice mechanism once the entity decision is finalised.

Contact for all legal, privacy, and Terms-related correspondence: Email: legal@bguru.app In-app: Settings → Help → Contact Us

Privacy Protection Authority (PPA / רשות להגנת הפרטיות) — regulatory contact: The Israeli supervisory authority for data-protection matters is the Privacy Protection Authority (PPA). Contact the PPA at: https://www.gov.il/en/departments/the_privacy_protection_authority or by post: Privacy Protection Authority, 3 Kaplan Street, Jerusalem 9195020, Israel.

Data Protection Officer (DPO): bGuru has not appointed a DPO at this stage. Appointment of a DPO is not mandatory under the Privacy Protection Law 5741-1981 / חוק הגנת הפרטיות, תשמ"א-1981 and Amendment 13 (effective August 2025) for an operator of bGuru's current scale and processing profile. We will appoint a DPO if and when our processing activities reach the scale or sensitivity thresholds that trigger mandatory appointment under Amendment 13. Until a dedicated privacy contact address is established, all DPO-equivalent inquiries should be directed to: legal@bguru.app.

Database registration status (PPL Amendment 13): At the date of these Terms, bGuru does not hold personal data on more than 10,000 Israeli residents, and does not hold sensitive personal data on more than 100,000 individuals anywhere. Database registration with the PPA is therefore not currently required under Amendment 13's simplified thresholds. bGuru monitors user-count growth against these thresholds on a weekly basis post-launch and will register the database promptly upon crossing either threshold.

Address for service in Israel: A specific Israeli postal address for legal service of process will be published in this section before bGuru's first paid tier launches, or sooner upon any binding regulatory request. In the meantime, legal notices addressed to legal@bguru.app and acknowledged via email constitute valid service for the purposes of these Terms, in addition to any other method of service permitted under Israeli law.

Once the formal entity is formed (per the §17.1 controller block above), this paragraph will be updated to disclose the entity's registered Israeli address (or, if the entity is incorporated outside Israel, a designated Israeli address for service distinct from the registered office) via the §16 material-change notice mechanism.

§17.2 European Union / EEA — Art. 27 representative

Under Article 27 of Regulation (EU) 2016/679 (GDPR), controllers established outside the EU/EEA who offer goods or services to, or monitor the behaviour of, individuals in the EU/EEA are required to designate a representative in the Union. bGuru, currently operated from Israel, falls within that requirement.

We are working to appoint an EU/EEA representative under GDPR Article 27. We will publish the name, address, and contact details of our appointed representative in this section once the appointment is confirmed. In the meantime, if you are a user in the EU/EEA with a data-protection question or request, please contact us directly at legal@bguru.app; we commit to responding within one month per GDPR Article 12(3).

Once an EU representative is appointed, they will be the first point of contact for EU/EEA data subjects and for supervisory authorities exercising their powers under GDPR Chapter VI. All EU/EEA data subjects retain the right to lodge a complaint with the supervisory authority of their member state of habitual residence regardless of which authority leads.

§17.3 United Kingdom — Art. 27 representative

bGuru's controlling entity is based in Israel and offers the Service to users in the United Kingdom. Under UK GDPR Art. 27 and the Data Protection Act 2018, a non-UK controller that targets UK users is required to appoint a representative in the United Kingdom.

We are working to appoint a UK representative under UK GDPR Art. 27 and DPA 2018. Their name, address, and contact details will appear at this section once appointed. Until that appointment is confirmed, UK users and the Information Commissioner's Office may contact us directly at legal@bguru.app for any data-protection query, and we commit to responding within one month per UK GDPR Art. 12(3).

§18 Changelog

Version	Effective date	Changes
0.1.10	2026-06-06	Added §4.3 Entertainment purpose — no gambling mechanics. Explicitly states that all prediction activities, scoring mechanisms, leaderboards, and Verified Tipster features are for entertainment and amusement only; not gambling, betting, games of chance, or financial activity; require no stake, entry fee, or payment; and award no money, goods, or anything of tangible value. Clarifies that decimal odds in the scoring formula are a mathematical ranking coefficient, not a wager. Includes a note distinguishing the disclaimer's role (good-faith corroboration of intent) from the actual legal protection (the no-benefit/no-prize/no-stake substance of the product design), and flags that a product change adding real-world value to any reward would require gambling-law review before implementation.
0.1.9	2026-06-03	Added §11 Third-party intellectual property: nominative fair use declaration covering all league, club, and competition marks displayed in the Service; explicit no-affiliation list (FIFA, UEFA, all major leagues and clubs); FIFA World Cup 2026 specific disclaimer; API-Football data-source disclosure; player rights of publicity and the factual-sports-reporting carve-out across US, EU, UK, Israel, and Australia; user-content prohibition against false-affiliation trademark misuse. Renumbered old §§11–17 to §§12–18; all internal cross-references updated.
0.1.8	2026-06-02	Refined the age-restricted ad-treatment description to use generic public wording rather than naming a specific Google SDK flag (§3). The substantive behaviour is unchanged. Collapsed the public changelog's pre-launch drafting iterations into a single summary entry for clarity.
0.1.7	2026-06-02	Refined §1 'no gambling mechanics' sentence to avoid contradicting itself.
0.1.6	2026-06-02	Clarified under-18 advertising posture (§3) — non-personalized contextual ads via Google AdMob NPA mode; age-restricted ad-treatment settings applied for users aged 16–17; behavioral/profiling-based ads will never be shown to users under 18 in any version.
Pre-launch drafting iterations	2026-05-30 → 2026-06-01	Multiple internal drafting iterations during the pre-launch review period. The substantive provisions described above were drafted, refined, and consolidated through this period.