Terms and conditions

Terms and conditions of platform usage

1. SERVICE PROVIDER IDENTIFICATION

Legal Name: INLAZE LTDA.
Trade Name: Commizzion
Corporate Taxpayer ID (CNPJ): 61.239.904/0001-69 (Headquarters)
General Inquiries: brasil@commizzion.com
Legal Notices: legal@commizzion.com
Data Protection Officer (DPO): dpo@commizzion.com
Governing Regulations: Marco Civil (Law 12,965/2014), Decree 8,771/2016, LGPD (Law 13,709/2018), Consumer Defense Code (CDC) where applicable, Law 14,790/2023, and regulations from the SPA/MF.

2. ACCEPTANCE AND PURPOSE

By using the Platform, the User agrees to these Terms and the Privacy Policy. Commizzion is not a betting operator; it is a B2B platform for campaign management, attribution, reporting, and payments.

3. RULES FOR BETTING ADVERTISING

Advertising is restricted to Operators authorized by the SPA/MF. It is strictly forbidden to target minors. All advertisements must include +18 notices and responsible gaming messages. Influencer partnerships must be transparently disclosed. Commizzion reserves the right to block any party that fails to demonstrate compliance, including the use of a .bet.br domain where applicable.

4. SERVICES AND PROHIBITED CONDUCT

Services: Campaign management, attribution/reporting, publisher payment settlement, and advertising compliance.
Prohibited Actions: Fraud/Invalid Traffic, interfering with platform security, violating intellectual property or laws, and circumventing Commizzion.

5. PAYMENTS AND TAXATION

The Operator pays Commizzion; subsequently, Commizzion pays the Publisher, net of any applicable withholdings and taxes. Payments are issued within 15 business days following confirmation from the Operator. Electronic invoices (NF-e) will be issued where required.

6. FRAUD/CHARGEBACKS AND PROCESS

Commizzion may suspend payments or links upon objective evidence of fraudulent activity. The affected party will have 5 business days to provide a defense. If fraud is confirmed, funds may be offset or withheld for up to 180 days.

7. PRIVACY, COOKIES, AND NOTICE & TAKEDOWN

LGPD roles are clearly defined. The platform utilizes a 2-layer cookie consent banner. Data logs are maintained in compliance with the Marco Civil. Content may be de-indexed upon receipt of a valid takedown notice.

8. LIABILITY, TERMINATION, AND DISPUTE RESOLUTION

Liability is capped at the total amount paid to the Publisher in the preceding three months, except in cases of willful misconduct or gross negligence. The agreement may be terminated for convenience with 15 days’ notice or for breach with a 5-day cure period. B2B disputes shall be resolved through arbitration at the CAM-CCBC in São Paulo. If consumer law applies, disputes will be handled in the appropriate consumer court.

1. PARTIES AND NATURE OF AGREEMENT

This agreement is between Commizzion (INLAZE LTDA., CNPJ 61.239.904/0001-69) and the approved Publisher. Commizzion acts as a marketplace and management platform, not a betting operator.

2. DEFINITIONS

Key terms include Attribution, Valid CPA, and Invalid Traffic (e.g., bots, self-referrals, manipulation, VPN/proxy usage, impersonation).

3. ONBOARDING AND COMPLIANCE

Publishers are subject to reasonable KYB/KYC reviews, as well as AML/CFT and sanctions screenings. Only Operators authorized by the SPA/MF are permitted on the platform.

4. ADVERTISING

All advertising must include +18 notices, responsible gaming messages, and clear disclosure of influencer partnerships. Geo-restrictions must be applied. Creatives require pre-approval, and non-compliant materials will be blocked automatically.

5. ATTRIBUTION, VALIDATION, AND REPORTING

Attribution windows are defined in the Commercial Addendum. Data is reconciled with Operator sources, and evidence may include logs, device IDs, and IP addresses.

6. PAYMENTS

Payments are issued within 15 business days, net of withholdings. The Publisher is responsible for providing all necessary fiscal documentation. Electronic invoices (NF-e) will be issued where applicable.

7. ADJUSTMENTS/CHARGEBACKS

8. INVALID TRAFFIC PROTOCOL

Upon objective evidence of invalid traffic, activity will be suspended. The Publisher has 5 days to submit a response. If the findings are upheld, commissions will be rejected/withheld. Repeated offenses will result in termination.

9. NON-CIRCUMVENTION

A non-circumvention clause is in effect for 24 months. A penalty of 20% of the revenue generated with the circumvented Operator will be applied.

10. IP, CONFIDENTIALITY, AND DATA

The Publisher retains ownership of their intellectual property, granting a limited license for use. Data processing is governed by the Privacy Policy and the DPA-LGPD.

11. LIABILITY AND TERMINATION

Liability is capped at 3 months of payments and excludes indirect damages. Termination may occur for convenience (15 days’ notice) or for breach (5-day cure period).

12. GOVERNING LAW AND DISPUTES

B2B disputes shall be resolved through confidential arbitration at the CAM-CCBC in São Paulo. Where consumer law applies, the case will be heard in the corresponding consumer court.