Terms of Service

Version 2026-09-23. These Terms govern the use of Stellar Reviews. Together with the Data Processing Agreement, the Privacy Notice and the Artificial Intelligence Notice they form the contract between the Customer and the Provider. This is a translation: if it differs from the Italian version, the Italian version prevails.

1. Who we are and definitions

1.1 Stellar Reviews (the "Service") is provided by Federico De Cillia, owner of the sole proprietorship GPT Chatbot di Federico De Cillia, Via Ernesto Teodoro Moneta 50, 20161 Milan, Italy, VAT IT13990330964, certified email (PEC) federico.decillia@spidmail.it, REA MI2755106, email info@flylabs.ai (the "Provider"). Stellar Reviews is presented under the FlyLabs brand.

1.2 In these Terms:

• Customer: whoever registers and accepts the Terms, for themselves or for the business they represent;
• User: any person the Customer authorises to use the Service;
• Property: the business (hotel, B&B, campsite, restaurant or similar) whose reviews the Customer manages;
• Platform: Google, TripAdvisor, Booking.com and the other supported review sites;
• Listing: the Property's page on a Platform;
• Draft: the reply to a review proposed by the Service;
• Plan: the chosen service level, free or paid;
• Link: Link, a Stripe service, which sells the paid Plans as merchant of record.

2. The Service

2.1 The Service collects the public reviews of the Listings indicated by the Customer, shows them in one place, prepares Drafts in the reviewer's language and in the Property's tone, translates them for the Customer and recognises when a reply has been published.

2.2 The Service does not publish replies: the Customer always publishes on the Platform. Any future automatic publishing, where a Platform allows it through official interfaces, will be optional, off by default and enabled only by an explicit choice of the Customer.

2.3 The features of each Plan (Platforms, Drafts per month, reading frequency, Users, support) are described on the pricing page and summarised before purchase.

3. Who may use the Service

3.1 The Service is intended for those acting for purposes related to the Property's activity, including non-entrepreneurial activity. By registering, the Customer declares this.

3.2 The Customer declares that it manages the Listings it connects, or is authorised by whoever manages them. Each Listing may have only one trial.

3.3 Whoever accepts the Terms on behalf of a business declares that they are authorised to do so.

3.4 If the Customer is a consumer, the protections that the law does not allow to be waived remain unaffected.

4. Account and security

4.1 Access takes place through a link sent by email or through the other methods offered by the Service. The Customer keeps its access secure and is responsible for its Users' activity.

4.2 The Customer invites Users within the limits of the Plan, assigns their roles and promptly reports any unauthorised use.

4.3 The Provider may access the Customer's account only for support, maintenance or security, or at the Customer's request. Every access is logged.

5. Plans, trial and payments

5.1 Trial. On first registration the Customer receives 14 days of the Premium Plan, without a card. When the trial ends, unless a paid Plan is activated, the account moves to the Free Plan at no cost.

5.2 Free Plan. It is free and includes one Listing and up to 2 Drafts per month. When more reviews arrive than are included, the Service reports their number and rating distribution; the text and Draft of those reviews are visible only with a paid Plan. The reviews always remain available on the Platform.

5.3 Quotas. Each Plan includes a number of Drafts per month per Property. Quota not used in the month is used automatically for reviews left unanswered, starting from the most recent and most critical; it does not carry over. Beyond the quota, new reviews are shown without a Draft until the Customer changes Plan or buys an add-on pack.

5.4 Purchase through Link. Paid Plans and add-on packs are sold by Link (Stripe), acting as reseller (merchant of record): it collects the price, calculates and remits taxes, issues the invoice or receipt and handles payments, refunds and disputes under its own terms, accepted at purchase. These Terms govern the use of the Service.

5.5 Prices. The prices on the pricing page at the time of purchase apply, excluding VAT for business customers; taxes are calculated by Link.

5.6 Plan changes. Upgrades take effect immediately, with a prorated charge for the current period. Downgrades take effect at the end of the period already paid.

5.7 Personal assistance. Services performed by people, such as assisted setup, are agreed and invoiced directly by the Provider.

6. Term, renewal and cancellation

6.1 The contract for the use of the Service has no fixed term. The Customer may delete the account at any time from the settings or by writing to the Provider.

6.2 Paid Plans, monthly or annual, renew automatically for a period of the same length unless cancelled before expiry. Cancellation is done in the app or in the Link customer area and takes effect at the end of the period already paid; from then on the account moves to the Free Plan. Before an annual Plan renews, the Customer receives a reminder.

6.3 Save as provided by law or by Link's terms, amounts paid for the current period are not refundable.

6.4 If a payment fails after the attempts made by Link, the account moves to the Free Plan.

7. Artificial intelligence and human review

7.1 Drafts are generated by an artificial intelligence system based on third-party models (currently Claude, by Anthropic). They are proposals: they may contain errors, inaccuracies or an unsuitable tone.

7.2 The Customer reads and, where needed, corrects every Draft before publishing it, and is responsible for it as the author of the published reply. For critical reviews the Draft is an outline to be completed.

7.3 As required by Article 50 of Regulation (EU) 2024/1689 (AI Act), the Service identifies Drafts as AI-generated in the interface, marks them in a machine-readable format where the format allows it, and records their generation. The Artificial Intelligence Notice describes how. The Customer does not remove the marking in the formats where it is present.

7.4 Drafts never promise refunds, discounts or compensation; the Customer does not edit them to do so without having decided it.

7.5 The Artificial Intelligence Notice contains instructions for use and known limitations.

8. Acceptable use

The Customer does not use the Service to:

• reply to reviews of properties it does not manage;
• create, solicit or publish fake or misleading reviews;
• publish replies that break the law, infringe third-party rights (including guests' privacy) or breach Platform rules;
• circumvent quotas, limits or security measures, or access the Service with automated tools not provided by the Provider;
• copy, decompile or resell the Service without a written agreement.

9. Data and confidentiality

9.1 For reviews and other personal data processed on the Customer's behalf, the Provider is the data processor under the Data Processing Agreement, which forms part of these Terms. The Customer is the controller and informs data subjects as required by law.

9.2 For account, security and AI Act register data, the Provider is the controller, as described in the Privacy Notice.

9.3 The Provider uses the Customer's data only to provide the Service. To improve it, it uses aggregate statistics that do not relate to individuals and, only after documented anonymisation, examples of the Customer's replies stripped of guest data. It never uses guest data for its own purposes or to train third-party models.

9.4 Each party keeps the other's non-public information confidential.

10. Intellectual property

10.1 The Service, software, prompts, trademarks and documentation belong to the Provider. The Customer receives a non-exclusive, non-transferable right of use for the term of the contract, within the limits of the Plan.

10.2 The Customer's content (data, settings, published replies) remains the Customer's. The Customer allows the Provider to use it to provide the Service and as set out in section 9.3.

10.3 The Customer may freely use the Drafts generated for it. The Provider does not warrant that a Draft is unique.

11. Availability, support and third-party providers

11.1 The Provider maintains the Service with professional diligence, without guaranteeing a minimum availability level unless otherwise agreed in writing for the Business Plan. There may be interruptions for maintenance, failures or external causes.

11.2 The Service depends on Platforms and third-party providers (data collection, AI models, hosting, email, payments). If a Platform changes or restricts access, the Provider may reduce or suspend reading that Platform, informing the Customer. If the reduction affects an essential feature of a paid Plan, the Customer may cancel with immediate effect and obtain a refund of the unused part of the period.

11.3 Support depends on the Plan: help centre and email; for the Business Plan, a reply within one business day.

12. Suspension and termination by the Provider

12.1 The Provider may suspend the account, giving notice where possible, if the Customer breaches section 8, for a security risk, at the request of an authority or if the use exposes the Provider to liability.

12.2 The Provider may withdraw from the contract with 30 days' notice, refunding through Link the unused part of paid Plans. If the Customer breaches section 8, the Provider may terminate the contract with immediate effect under Article 1456 of the Italian Civil Code.

12.3 A Free account inactive for more than 12 months may be closed with at least 30 days' notice.

13. Limitation of liability

13.1 The Provider is not liable for the content of replies published by the Customer, for Platform decisions (removal of replies, blocks, ranking changes), for indirect damage, loss of profit, bookings or reputation, or for interruptions caused by third-party providers or events beyond its control.

13.2 For any other damage, the Provider's total liability does not exceed the amounts paid by the Customer for the Service in the 12 months before the event, or EUR 100 for free Plans.

13.3 These limitations do not apply in case of wilful misconduct or gross negligence (Article 1229 of the Italian Civil Code) or where the law does not allow them.

14. Indemnity

The Customer holds the Provider harmless from third-party claims, penalties and costs, including legal fees, arising from the replies it publishes, from a breach of section 8 or from connecting Listings it does not manage.

15. Changes

15.1 The Provider may improve and change the Service. Changes that substantially reduce a paid Plan apply from the next renewal, with 30 days' notice.

15.2 The Provider may change the Terms and prices with at least 30 days' notice, by email or in the app; new prices apply from the first renewal after the notice. If it does not accept them, the Customer may cancel at no cost before they take effect. Changes required by law may apply earlier.

16. End of contract and data export

16.1 At the end of the contract the Customer may request an export of its data within 30 days; after that the data is deleted as set out in the Data Processing Agreement.

16.2 The register under section 7.3 and data that the law requires to be kept are retained.

17. Notices

Notices to the Customer go to the account email or appear in the app. Notices to the Provider go to info@flylabs.ai or to the certified email in section 1.

18. Governing law and jurisdiction

18.1 Italian law applies.

18.2 For any dispute with business customers the courts of Milan have exclusive jurisdiction. For consumers, the court provided by the law for their protection remains competent.

19. Final provisions

19.1 The Terms, Data Processing Agreement, Privacy Notice and Artificial Intelligence Notice are the entire agreement for the use of the Service; the purchase of Plans is also governed by Link's terms.

19.2 The Customer agrees in advance that the Provider may assign the contract to a business or company taking over the Service (Article 1407 of the Italian Civil Code). The assignment is notified to the Customer, who may cancel at no cost if it does not accept it.

19.3 If a clause is invalid, the others remain valid. Not enforcing a clause is not a waiver.

19.4 The contract is concluded online by accepting the Terms at registration; before confirming, the Customer can correct the data entered. The accepted version remains available in the account and at this address. The Provider does not adhere to codes of conduct.

19.5 The Terms are available in Italian and English; if they differ, the Italian version prevails.

20. Specific approval

Pursuant to Articles 1341 and 1342 of the Italian Civil Code, the Customer specifically approves: section 6.2 (automatic renewal); section 6.3 (non-refundable amounts); section 7.2 (Customer's responsibility for published replies); section 11.2 (reduced reading of Platforms); section 12 (suspension and termination by the Provider, express termination clause); section 13 (limitation of liability); section 14 (indemnity); section 15 (unilateral changes to the Service, Terms and prices); section 18.2 (exclusive jurisdiction); section 19.2 (assignment of the contract).