Legal · Imprint

Imprint

Operator identity, legal registration, contact and dispute-resolution information for the 99 Pelicans Puzzle Roadtrip. Published in accordance with German Telemediengesetz (TMG) § 5, Austrian E-Commerce Act (ECG) § 5 and applicable transparency obligations under Regulation (EU) 2022/2065 (Digital Services Act).

Effective Date: [TO BE FILLED] · Version 1.0

Operator of this Website

The website https://99pelicans.com and the 99 Pelicans Challenge System are operated by:

Company name
LIMITED LIABILITY COMPANY “SMART EXPERIENCE”
Legal form
Limited Liability Company (Товариство з обмеженою відповідальністю) under the laws of Ukraine
Registered office
Ukraine, city Kyiv, street Polova, building 24
Company registration number
46145133 (Unified State Register of Legal Entities of Ukraine — EDR)
VAT / Tax status
Not registered for Ukrainian Value Added Tax (PDV). EU Value Added Tax on B2C sales to consumers in the European Union is collected and remitted by the appointed Seller of Record (see § 04) under the EU One-Stop-Shop (OSS) / Mini One-Stop-Shop (MOSS) schemes, in accordance with Council Directive (EU) 2017/2455 and Council Implementing Regulation (EU) 282/2011.
Authorised representative
Oleksii Tarasevych, Chief Executive Officer
Email
hello@99pelicans.com
Rapid electronic contact
Email above. The Developer does not operate a telephone consumer line; consumer enquiries are handled exclusively in writing through hello@99pelicans.com, with an acknowledgement target of two (2) business days. The German Federal Court of Justice (BGH) ruled on 16 October 2019 (case I ZR 163/17) that email may satisfy the “direct and effective communication” requirement of TMG § 5(1) no. 2 where a telephone line is not maintained, provided the alternative channel is acted upon promptly.
Website
https://99pelicans.com

For the purposes of these legal notices, the operator above is referred to as the “Developer”.

Person Responsible for Editorial Content

The person responsible for journalistic and editorial content on this website within the meaning of § 18 paragraph 2 of the German Medienstaatsvertrag (MStV) and § 5 of the Austrian ECG is:

Name
Oleksii Tarasevych
Role
Chief Executive Officer, LIMITED LIABILITY COMPANY “SMART EXPERIENCE”
Address
c/o LIMITED LIABILITY COMPANY “SMART EXPERIENCE”, Ukraine, city Kyiv, street Polova, building 24
Email
hello@99pelicans.com

EU Representative under Article 27 GDPR

As the Developer is established outside the European Union and processes personal data of data subjects in the European Union in connection with offering services to them, the Developer designates the following representative in the Union under Article 27 of Regulation (EU) 2016/679 (GDPR):

Status
[TO BE CONFIRMED — either name the appointed Article 27 EU Representative (company, EU address, contact), or replace this section with a statement that processing falls under the Article 27(2) exemption]
Why this matters: An EU Representative is required for non-EU controllers processing EU residents’ data, except where processing is occasional, does not include large-scale special categories, and is unlikely to result in a risk to data subjects. For consumer marketing and account processing across DE, AT, IT, NL and PL, the exemption is typically not available. Specialised EU Rep services (e.g., EDPO, DPRC, Prighter) start at approx. €500–€1 500 per year.

Seller of Record & Payment Processing

All sales, invoicing, EU VAT collection and remittance, consumer billing support and payment processing for licenses to the 99 Pelicans Challenge System are executed by the Seller of Record contracted by the Developer (the “Seller”):

Seller of Record
[TO BE FILLED — legal name and registered address of the appointed Merchant of Record (e.g., FastSpring, Inc., 801 Garden Street, Suite 201, Santa Barbara, CA 93101, USA) upon formal approval]
Role
Independent merchant and data controller for the payment transaction. The Seller appears as the merchant on the User’s card or bank statement, issues the legally compliant tax invoice, and is responsible for EU VAT / OSS, MOSS and equivalent tax obligations.
Seller support
Contact details for billing support are stated on the User’s invoice and on the Seller’s own consumer support portal.

The Developer is not authorised to debit, charge, capture or refund payment instruments directly and acts solely as the supplier of the underlying digital intellectual content.

Hosting and Infrastructure

The website and the 99 Pelicans Challenge System are operated on cloud and shared hosting infrastructure provisioned to the Developer by:

Hosting provider
LIMITED LIABILITY COMPANY “KHMARA” (Ukrainian: Товариство з обмеженою відповідальністю «ХМАРА»), trading as “Tucha”
Registered office
Kniazhyi Zaton St. 16B, 02095 Kyiv, Ukraine
Registration number
EDRPOU 39481519 (Unified State Register of Legal Entities of Ukraine)
Website
https://tucha.ua / https://tucha.cloud
Data residency
Primary servers and persistent operational data are located within the territory of Ukraine.
Transfer mechanism for EU/EEA personal data
As Ukraine has not received a finalised adequacy decision from the European Commission under Article 45 GDPR, transfers of personal data of EU/EEA data subjects to the hosting infrastructure of Tucha are made under Article 46 safeguards — principally the Standard Contractual Clauses adopted in Commission Implementing Decision (EU) 2021/914, supplemented by technical measures (TLS 1.2+, encryption-at-rest, role-based access control, audit logging) and organisational measures (confidentiality undertakings, access reviews, documented incident-response).

Further details on personal-data processing, sub-processors and international transfers are set out in the Privacy & Data Protection Policy.

Nature of the Service

The 99 Pelicans Challenge System is a digital access license to a proprietary Intellectual Navigation & Scoring System (clues, geographic coordinates, scoring engine), together with complementary Supplementary Printed Materials handed over to Team members in person at the official Series activation event.

The Developer is a software and content supplier. The Developer does not organise, sell, resell, broker or operate:

Accordingly, the Developer is not a travel agent, tour operator or organiser of package travel and does not hold travel-trade licences, package-travel insolvency protection or any equivalent registration. Teams independently arrange and finance all of their own travel logistics, accommodation, catering and insurance.

Online Dispute Resolution & Consumer Complaints

In accordance with Article 14(1) of Regulation (EU) 524/2013 on consumer Online Dispute Resolution, the European Commission provides an ODR platform at:

The Developer’s contact email for ODR purposes is hello@99pelicans.com. The Developer is willing to engage in good-faith resolution. The Developer is not obliged and not willing to participate in dispute resolution proceedings before a consumer arbitration board within the meaning of the German Verbraucherstreitbeilegungsgesetz (VSBG).

Statutory rights of EU/EEA consumers under Directive 2011/83/EU (Consumer Rights Directive) including the 14-day right of withdrawal are addressed in the Cancellation & Refund Policy.

Liability for Own Content

The content of this website has been prepared with care. The Developer is responsible for its own content on this website in accordance with § 7 paragraph 1 of the German TMG and general legislation. Under §§ 8 to 10 TMG, however, the Developer as a service provider is not obliged to monitor transmitted or stored third-party information, or to investigate circumstances suggesting unlawful activity. Obligations to remove or block the use of information under general law remain unaffected. Liability in this respect arises only from the moment a specific infringement becomes known. Upon notification of any such infringement, the content concerned will be removed without undue delay.

Liability for External Links

This website contains hyperlinks to third-party websites whose content is outside the Developer’s control. At the time the links were established, the linked pages were reviewed for potential legal violations and no unlawful content was identifiable. Continuous monitoring of the content of linked websites without specific indication of an infringement is not reasonable. If any infringement becomes known, such links will be removed without undue delay.

Copyright

All content and works on these pages prepared by the Developer — including text, images, graphics, the “99 Pelicans” word and logo marks, route designs, scoring methodology, and the Intellectual Navigation & Scoring System — are protected by Ukrainian and international copyright, trademark and database rights. Reproduction, editing, distribution and any form of commercial exploitation outside the licensed scope of the System require the prior written consent of the Developer. Downloads and copies of this website are permitted only for private, non-commercial use.

Image Credits

Where third-party photography is used on this website (e.g., scenic landscape photography on the homepage and Series pages), images are licensed from Pexels and used in accordance with the Pexels Content License. Logo, branded assets and original photography are property of the Developer.

Updates to this Imprint

The Developer may update this Imprint from time to time to reflect changes in legal requirements, operator details, sub-processor arrangements or the appointed Seller of Record and EU Representative. The current version is always available at https://99pelicans.com/imprint with the Effective Date and Version number.