Pauhu LDS Connector — End User License Agreement

Version 1.0 · Last updated: March 6, 2026

Parties

Licensor: Pauhu Ltd, Business ID 0768171-8, Helsinki, Finland (“Pauhu”)

Licensee: As identified in the Order Form (“Customer”)

Recitals

1. Pauhu has developed a proprietary language data processing platform that processes, annotates, and distributes EU institutional data feeds through containerized connectors.
2. Customer wishes to access EU institutional data feeds through Pauhu’s LDS-compatible connector for internal use within its organisation.
3. This Agreement governs the license to use the Pauhu LDS Connector software and access to annotated data feeds. Underlying EU source data is separately licensed under the Data Use Terms.

1. Definitions

1.1. “Connector” means the Pauhu LDS Connector software delivered as a container image (Docker/OCI format), including the entrypoint, configuration files, and pre-loaded ONNX model weights, but excluding Source Code.

1.2. “Container Modes” means the six (6) operational configurations available under this Agreement:

• (a) Feeds (pauhu.eu) — LDS data connector + annotation pipeline
• (b) Chat (pauhu.ai) — RAG chat with EU regulatory grounding
• (c) Translate (pauhu.com) — Translation cascade with Helsinki-NLP models
• (d) Developer (pauhu.dev) — IDE integration with EU context
• (e) Industrial (pauhu.io) — Air-gapped IEC 62443 for OT/ICS
• (f) Search (pauhu.com) — Compass search engine access

1.3. “Source Code” means human-readable programming code, algorithms, architectures, and design documents of the Connector, including but not limited to:

• (a) The cascade orchestration logic
• (b) The deontic gate classification algorithms (M1/M2/M3/M4)
• (c) The search algorithm
• (d) The information filtering algorithm
• (e) The annotation pipeline implementation
• (f) The domain classifier training methodology
• (g) The translation cascade 10-stage ISO 18587 workflow
• (h) The gate health monitoring system

1.4. “Annotated Data” means EU institutional data enriched with Pauhu’s proprietary annotations (deontic classification, policy stance, topic classification, provenance metadata).

1.5. “Updates” means bug fixes, security patches, and minor version releases (x.Y.z) of the Connector provided during the Subscription Term.

1.6. “Upgrades” means major version releases (X.0.0) that may be offered separately.

2. License Grant

2.1. Limited License. Subject to Customer’s compliance with this Agreement and payment of applicable Fees, Pauhu grants Customer a non-exclusive, non-transferable, non-sublicensable license to:

• (a) Deploy the Connector on Customer’s own infrastructure within the European Economic Area (EEA);
• (b) Use the Connector in the Container Modes specified in the Order Form;
• (c) Connect the Connector to Customer’s internal systems via the documented API;
• (d) Access Annotated Data feeds as specified in the applicable data subscription tier (per Data Use Terms).

2.2. Permitted Users. The license extends to Customer’s employees and authorised contractors who have agreed to confidentiality obligations at least as protective as this Agreement. Maximum concurrent users as specified in the Order Form.

2.3. Deployment Restrictions.

• (a) The Connector MUST be deployed on infrastructure located within the EEA or an EU-adequate jurisdiction (Commission adequacy decision per GDPR Art. 45).
• (b) Air-gapped deployments (Industrial mode) are permitted within any jurisdiction, provided the Connector does not connect to external networks.
• (c) Customer MUST NOT deploy the Connector on infrastructure controlled by a non-EU entity subject to foreign government data access laws that conflict with GDPR Chapter V.

3. Intellectual Property Reservation

3.1. Pauhu Retains All IP. The Connector is licensed, not sold. Pauhu retains all right, title, and interest in and to the Source Code (as defined in Section 1.3), the cascade architecture and all gate logic, the search and filtering algorithms, the annotation schema and provenance chain, all model weights, training data curation methodology, and fine-tuning hyperparameters, and all patents, patent applications, trade secrets, copyrights, and trademarks related to the above.

3.2. No Reverse Engineering. Customer SHALL NOT:

• (a) Decompile, disassemble, reverse engineer, or otherwise attempt to derive Source Code from the Connector;
• (b) Modify, adapt, translate, or create derivative works based on the Connector;
• (c) Remove, alter, or obscure any proprietary notices, labels, or markings;
• (d) Use the Connector to develop a competing product or service;
• (e) Benchmark the Connector against competing products without Pauhu’s prior written consent;
• (f) Extract, copy, or redistribute model weights or ONNX files from the Connector image;
• (g) Attempt to reconstruct training data, fine-tuning methodology, or annotation schemas from Connector outputs.

3.3. Prohibited Uses. Customer SHALL NOT use the Connector, any Annotated Data, or any outputs for:

• (a) Surveillance, tracking, or monitoring of individuals, including but not limited to locating, profiling, or identifying natural persons for intelligence, law enforcement, or military purposes;
• (b) Development or operation of weapons systems, military targeting, or lethal autonomous systems;
• (c) Mass surveillance, social scoring, or biometric identification in public spaces;
• (d) Any purpose that violates the EU AI Act (Regulation (EU) 2024/1689) Article 5 prohibited practices;
• (e) Any purpose that violates fundamental rights as recognised by the EU Charter of Fundamental Rights, including the right to life (Art. 2), the right to liberty and security (Art. 6), and the right to protection of personal data (Art. 8).

Violation of this Section 3.3 constitutes a material breach entitling Pauhu to immediate termination under Section 7.2 without cure period.

3.4. Output Ownership. Customer owns the outputs generated by the Connector when applied to Customer’s own data. Customer does NOT own Annotated Data derived from EU institutional sources (governed by Data Use Terms and source licenses), terminology lookups (EU institutional data, CC-BY 4.0), or deontic classifications applied to EU source data.

4. Data Licensing

4.1. EU Source Data. The underlying EU institutional data accessed through the Connector is licensed under the terms set out in the Data Use Terms schedule, which is incorporated by reference.

4.2. Annotation Layer. Pauhu’s proprietary annotations (deontic category, policy stance, confidence scores, provenance metadata) are Pauhu trade secrets applied on top of CC-BY 4.0 source data. Customer may use annotation outputs but may not redistribute the annotation methodology or schemas, use annotations to train a competing classification model, or strip annotations from source data and resell the annotations separately.

4.3. Customer Data. If Customer uploads its own data (TMX, TBX, documents) to the Connector for processing, Customer retains full ownership. Pauhu processes Customer data solely under the Joint Controllership Agreement (Annex A) and does not retain Customer data beyond the processing session unless explicitly agreed.

5. Subscription and Fees

5.1. Subscription Model. The Connector is licensed on an annual subscription basis. Fees are specified in the Order Form and are based on Container Modes selected, data subscription tier, number of permitted users, and deployment count.

5.2. Payment Terms. Invoiced annually in advance. Net 30 days. Late payment: ECB reference rate + 8 percentage points (Late Payment Directive 2011/7/EU).

6. Support and Updates

6.1. Included Support. During the Subscription Term, Pauhu provides:

• (a) Security patches and bug fixes (within 48 hours for Critical, 7 days for High);
• (b) Minor version updates (quarterly);
• (c) Email support (support@pauhu.eu, response within 2 business days);
• (d) Documentation access;
• (e) Data feed continuity (sync workers maintain freshness per cron schedules).

6.2. Excluded. This Agreement does NOT include on-site support or professional services, custom model training or fine-tuning, integration with Customer’s proprietary systems (available as separate engagement), major version Upgrades (offered at renewal), or SLA guarantees (available as separate addendum).

7. Term and Termination

7.1. Term. Initial term as specified in Order Form (minimum 12 months). Auto-renews for successive 12-month periods unless either Party provides 90 days’ written notice before renewal.

7.2. Termination for Breach. Either Party may terminate if the other materially breaches and fails to cure within 30 days of written notice.

7.3. Termination for Insolvency. Either Party may terminate immediately if the other becomes insolvent, enters liquidation, or makes an assignment for the benefit of creditors.

7.4. Effect of Termination.

• (a) Customer must delete all copies of the Connector image within 30 days;
• (b) Customer retains outputs generated during the Subscription Term (subject to Section 3.3);
• (c) Pauhu retains the right to audit compliance with deletion obligation;
• (d) Sections 3, 8, 9, 10, and 11 survive termination.

8. Warranties and Disclaimers

8.1. Pauhu Warrants:

• (a) The Connector will perform materially as described in the documentation;
• (b) Pauhu has the right to grant the licenses in this Agreement;
• (c) The Connector does not, to Pauhu’s knowledge, infringe any third-party intellectual property rights in the EEA;
• (d) Security patches will be provided in accordance with IEC 62443-3-3 vulnerability management procedures.

8.2. Disclaimers.

• (a) EU source data is provided “AS IS” from EU institutions. Pauhu does not warrant the accuracy, completeness, or timeliness of source data;
• (b) Annotations are probabilistic classifications, not legal advice. Customer is responsible for verifying classifications against authoritative legal sources. No automated individual decisions (GDPR Art. 22) should be made solely on the basis of Connector outputs;
• (c) EXCEPT AS EXPRESSLY SET FORTH IN SECTION 8.1, THE CONNECTOR IS PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED.

9. Liability

9.1. Cap. Pauhu’s total aggregate liability under this Agreement shall not exceed the total Fees paid by Customer in the 12 months preceding the claim.

9.2. Exclusions. Neither Party shall be liable for indirect, incidental, consequential, special, or punitive damages, including lost profits, lost data, or business interruption.

9.3. Exceptions. The limitations in 9.1 and 9.2 do not apply to breach of Section 3 (IP protection) by Customer, willful misconduct or gross negligence, or liability that cannot be limited under applicable Finnish law.

10. Confidentiality

10.1. Each Party shall maintain the confidentiality of the other’s Confidential Information for the duration of this Agreement and 5 years thereafter.

10.2. Pauhu Confidential Information includes (without limitation): Source Code (Section 1.3), annotation schemas and provenance methodology, model architecture and training methodology, pricing structures not publicly available, and Customer list and usage data.

10.3. Exclusions. Information that is publicly available, independently developed, or received from a third party without restriction.

11. Governing Law and Dispute Resolution

11.1. This Agreement is governed by Finnish law, excluding its conflict of law provisions.

11.2. Disputes shall be resolved by the Helsinki District Court (Helsingin käräjäoikeus), unless the Parties agree to arbitration under the Arbitration Institute of the Finland Chamber of Commerce.

Annexes

• Annex A: Joint Controllership Agreement (Art. 26 GDPR) — governs personal data processing responsibilities between Pauhu and Customer
• Annex B: Data Use Terms — source-by-source licensing for 20 EU institutional data feeds
• Annex C: Order Form — completed per customer engagement (Container Modes, data tier, user count, deployment count, annual fee, term, deployment jurisdiction)

Pauhu Ltd · Helsinki, Finland · EU jurisdiction
legal@pauhu.eu