Terms of Use

1. INTRODUCTION

1.1. “Anya” is the product name for 360hubspot Media & Project Services Limited (“the Company”). 360hubspot operates a media-buying and e-commerce platform consisting of a website and application for the sale and purchase of advertising products and services (“products”) in its allocated territory.

1.2. These general terms and conditions shall apply to buyers and vendors on the marketplace and shall govern your use of the marketplace and related services.

1.3. By using our marketplace, you accept these general terms and conditions in full.

1.4. If you use our marketplace in the course of a business or other organizational project, you confirm you have obtained the necessary authority to bind that legal entity to these terms.

2. REGISTRATION AND ACCOUNT

2.1. You may not register with our marketplace if you are under 18 years of age.

2.2. You agree to keep your password confidential and notify us immediately of any unauthorized disclosure.

2.3. Your account shall be used exclusively by you. We may suspend or cancel your account at our sole discretion, providing that if we cancel services you have paid for (and you are not in breach), we will refund you in respect of the same.

3. TERMS OF SALE & PLATFORM ROLE

3.1. The Marketplace Model: You acknowledge that the marketplace provides an online location for Vendors to sell and Buyers to purchase products. Unless Anya is explicitly indicated as the Vendor, Anya is not a party to the transaction between the Vendor and the Buyer.

3.2. Agency & Revenue Definition: Anya operates as a technology intermediary. For all transactions:

• Service Fee: The Anya Service Fee (the 14% platform commission) constitutes the gross revenue of the Company for its facilitation services.
• Disbursements: All other funds, including but not limited to Media Space costs, ARCON Vetting Fees, and Logistics costs, are classified as Pass-Through Disbursements.
• Limited Paying Agent: By confirming a purchase, the Buyer appoints the Company as its Limited Paying Agent. The Company receives these Disbursement funds in trust and remits them to the respective third-party Vendors or Regulatory bodies on the Buyer’s behalf. These funds do not constitute income or turnover for the Company.

4. ARCON VETTING & REGULATORY COMPLIANCE

4.1. Mandatory Approval: In accordance with the ARCON Act 2022, all advertisements must be vetted by the Advertising Standards Panel (ASP) before exposure.

4.2. Optional Facilitation: Anya offers an optional service to facilitate the payment of ARCON vetting fees. This is a payment convenience only and does not shift legal responsibility for content approval to the Company.

4.3. User-Provided Evidence: Where a Buyer does not opt for platform vetting facilitation, the Buyer must provide digital evidence of a valid ARCON Certificate of Approval for the material being booked.

4.4. Indemnity for Non-Compliance: If a campaign is executed without a valid ARCON certificate because the Buyer failed to provide evidence or pay the fee, Anya shall not be held liable for any resulting fines, sanctions, or takedown orders. The Buyer assumes all legal risks and indemnifies the Company against any such regulatory penalties.

5. CANCELLATIONS AND REFUNDS

5.1. Cancellation and refunds shall be managed in accordance with the rules on our website.

5.2. In respect of digital products or media services, Anya shall issue refunds in respect of failures in delivery only, and only where the Buyer cancels within 24 hours of payment. All other refunds are subject to the Vendor’s terms and conditions of sale.

6. PAYMENTS & FINANCIAL INTEGRITY

6.1. Transaction Pricing: All listed service prices are inclusive of a 14% Anya Service Fee. Additional services (e.g., Measurement) and ARCON fees are priced separately.

6.2. Regulatory Reporting: As part of our commitment to preventing financial crimes, activity suspected to be linked to money laundering will be reported to the Economic and Financial Crimes Commission (EFCC) and the FCPCC in line with applicable laws.

6.3. We reserve the right to delay or withhold processing of any transaction or refund request until all due diligence verification processes are completed.

7. STORE CREDIT & PROMOTIONS

7.1. Store Credits: Earned and managed per the Anya Store Credit Terms. We reserve the right to cancel rewards for any reason, including suspected fraud.

7.2. Promotions: Competitions run by Anya or other promoters shall be managed in accordance with specific Promotion Terms and Conditions published on the website.

8. RULES ABOUT YOUR CONTENT

8.1. Your content must be accurate, truthful, and civil.

8.2. Your content must not be illegal, infringe on any person’s legal rights (including intellectual property), or be capable of giving rise to legal action.

8.3. You must not use our marketplace to link to any website that breaches these terms or to contact other users to complete transactions outside of the marketplace.

9. OUR RIGHTS TO USE YOUR CONTENT

9.1. You grant to us a worldwide, irrevocable, non-exclusive, royalty-free license to use, reproduce, and distribute your content across our marketplace and marketing channels for the execution of your campaign.

10. USE OF WEBSITE AND MOBILE APPLICATIONS

10.1. You may only use our website for your own personal and business purposes in respect of selling or purchasing products on the marketplace.

10.2. You must not conduct any systematic or automated data collection activities (scraping, data mining) without our express written consent.

11. COPYRIGHT AND TRADEMARKS

11.1. We, together with our licensors, own and control all the intellectual property rights in our website and the material on our website.

12. DUE DILIGENCE AND AUDIT RIGHTS

12.1. You agree to provide all such information and documentation as we may require to verify your adherence to these terms or for disclosures required by a court or governmental body.

13. LIMITATIONS AND EXCLUSIONS OF LIABILITY

13.1. Nothing in these terms will limit or exclude liabilities in any way that is not permitted under applicable law.

13.2. Our aggregate liability to you in respect of any contract shall not exceed the total Anya Service Fee paid and payable to us under that specific contract.

13.3. We will not be liable for losses arising out of events beyond our reasonable control, business losses, or loss of data.

14. INDEMNIFICATION

14.1. You hereby indemnify us against any and all losses, costs, and liabilities arising directly or indirectly out of your use of our marketplace or any breach by you of these terms.

14.2. This includes any VAT or other tax liability we may incur due to your failure to pay, withhold, or declare taxes properly due in any jurisdiction.

15. BREACHES OF THESE TERMS

15.1. If you breach these terms, we may temporarily or permanently prohibit your access to the marketplace, suspend your account, or commence legal action.

16. ADMINISTRATIVE CLAUSES

16.1. Entire Agreement: These terms and our policies constitute the entire agreement between you and us.

16.2. Hierarchy: In the event of a conflict, these General Terms shall prevail over Vendor terms or other guidelines.

16.3. Variation: We may revise these terms from time to time. Revised terms apply from the date of publication.

16.4. No Waiver: No waiver of any breach shall be construed as a continuing waiver of any other breach.

16.5. Severability: If a provision is determined to be unlawful or unenforceable, the other provisions will continue in effect.

16.6. Assignment: You agree that we may assign or sub-contract our rights and obligations. You may not do so without our written consent.

16.7. Third-Party Rights: These terms are for our benefit and your benefit and are not intended to benefit or be enforceable by any third party.

17. LAW AND JURISDICTION

17.1. These terms shall be governed by and construed in accordance with the laws of the territory (Federal Republic of Nigeria).

17.2. Any disputes shall be subject to the exclusive jurisdiction of the courts of the territory.

NB: Updated December, 2025

28. Appendix 1