Terms and Conditions

Legal framework applicable to the use of the Site and to the purchase of any product or service marketed through bluego.io. Text drafted in accordance with Directive 2011/83/EU, Directive (EU) 2019/2161 (the "Omnibus" Directive), Directive (EU) 2019/770 on digital content and digital services, Regulation (EU) 2022/2065 (DSA) and the Estonian law of obligations (Võlaõigusseadus, VÕS).

2.1. Acceptance of the conditions

The use of the Site and the placement of any order imply full and unreserved acceptance of these terms and conditions, as well as, where applicable, the specific terms applicable to the product or service purchased (eSIM, Flight Compensation, BlueCoins and coupons).

Acceptance is expressed by expressly ticking the checkboxes provided for this purpose during the purchase process. Each acceptance is recorded with the IP address, timestamp and version hash of the accepted terms, as required by the principle of accountability under Article 5(2) of the GDPR, generating an immutable audit trail ("consent log").

2.2. Capacity to contract

The User declares that they are at least 18 years old or have reached the age of majority required in their jurisdiction of residence and possess full legal capacity to assume the obligations arising from this contract. Contracts entered into by minors or persons whose legal capacity has been judicially modified shall require the corresponding legal assistance or representation. BlueGo Solutions OÜ does not intentionally collect personal data from children under 13 years of age, in accordance with Article 8 of the GDPR.

2.3. Definitions

Platform or Site
The website bluego.io, as well as any mobile application, customer panel and associated subdomains.
User
Any natural or legal person who accesses the Site, regardless of whether they place an order.
Customer or Consumer
A natural person acting for purposes outside their trade, business, craft or profession, within the meaning of Article 2(1) of Directive 2011/83/EU and § 1, paragraph 5, of the Estonian Consumer Protection Act.
Services
All products marketed by BlueGo Solutions OÜ, including eSIM, Flight Compensation and other ancillary products.
Underlying provider
A third party that materially provides the purchased service (eSIM providers, AirHelp, Stripe, among others).
Digital content
Any data produced or supplied in digital format, in accordance with Article 2.1 of Directive (EU) 2019/770; in the context of BlueGo, the eSIM profile and the activation QR code are considered digital content.

2.4. Purchase process

The purchase procedure is conducted, in accordance with Article 8 of Directive 2011/83/EU, according to the following stages:

  1. Selection of the main product (eSIM plan by country and data volume).
  2. Selection, where applicable, of ancillary products (Flight Compensation or other products that BlueGo Solutions OÜ may offer in due course).
  3. Order summary with a breakdown of prices, taxes and final total, including any ancillary charges.
  4. Granular acceptance of the specific terms applicable to each product purchased.
  5. Payment through the methods available via Stripe Payments Europe Limited.
  6. Electronic confirmation of the order and delivery of the purchased digital content (in the case of eSIM, an activation QR code sent by email immediately upon payment confirmation).

Before placing the order, the User may identify and correct any errors in the data entered. The final payment button shall bear the clear indication "order with obligation to pay", in accordance with Article 8(2) of Directive 2011/83/EU.

2.5. Prices, taxes and invoicing

All prices displayed on the Site are expressed in euros (EUR), unless the User activates the multi-currency converter, in which case the price shown in other currencies shall be for informational purposes only (see Section 09). Prices include applicable indirect taxes where required by law.

The VAT regime applicable to each order shall be one of the following:

  • EE_DOMESTIC: customers domiciled in Estonia — standard Estonian rate of 24%.
  • EU_REVERSE_CHARGE: business customers with a VAT number validated in the VIES database (VAT Information Exchange System) — 0%, under the reverse charge mechanism.
  • EU_OSS_B2C: individual consumers resident in another Member State of the European Union — rate of the country of destination, under the One Stop Shop (OSS) regime regulated in Articles 369a et seq. of Directive 2006/112/EC.
  • OUT_OF_SCOPE_EU: customers resident outside the European Union — transaction not subject to Estonian VAT.

The electronic invoice shall be issued upon payment confirmation and sent to the Customer's email address, in compliance with § 37 of the Estonian VAT Act (Käibemaksuseadus).

2.6. Payment methods

Payment processing is carried out entirely through Stripe Payments Europe Limited, an entity authorised as an electronic money institution by the Central Bank of Ireland in accordance with Directive (EU) 2015/2366 (PSD2). BlueGo Solutions OÜ does not store complete payment card data on its systems: the entire payment flow takes place within Stripe's PCI DSS Level 1 environment.

Available payment methods include, among others, Visa, Mastercard and American Express cards, Apple Pay, Google Pay, Alipay, WeChat Pay and JCB. Strong Customer Authentication (SCA) shall be applied where required by Article 97 of Directive (EU) 2015/2366 and the regulatory technical standards of the European Banking Authority.

2.7. Delivery of digital content

The eSIM is delivered as digital content supplied on a non-tangible medium, within the meaning of Article 5 of Directive (EU) 2019/770 and § 53, paragraph 4, point 8, of the Võlaõigusseadus (Law of Obligations Act). Delivery is made electronically to the email address provided by the Customer, in the form of an activation QR code, installation instructions and manual configuration data for the eSIM profile.

2.8. Warranties and conformity

BlueGo Solutions OÜ warrants that the Services shall be supplied as described on the Site at the time of purchase, in accordance with Directive (EU) 2019/770 on digital content and digital services and Chapter 11 of the Võlaõigusseadus (Law of Obligations Act). In the event of a lack of conformity, the Customer may require that the Service be brought into conformity, a price reduction or termination of the contract, in accordance with the legally established criteria and time limits. The legal warranty is provided at no additional cost to the Customer.

2.9. Liability and limitations

BlueGo Solutions OÜ shall be liable for direct and foreseeable damages arising from the breach of its contractual obligations, within the limits permitted by applicable law. Indirect damages, loss of profit, loss of opportunity or moral damages are expressly excluded, unless they arise from wilful misconduct or gross negligence on the part of the provider and always within the limits permitted by § 106 et seq. of the Võlaõigusseadus (Law of Obligations Act).

The maximum cumulative liability of BlueGo Solutions OÜ towards a Customer, for any cause related to a specific order, shall not exceed the amount actually paid by the Customer for the order in question, except in those cases where such limitation is prohibited by mandatory law, especially where the Customer holds the status of a consumer.

2.10. Force majeure

BlueGo Solutions OÜ shall not be liable for any failure or delay in the performance of its obligations where such failure or delay is due to force majeure circumstances, understood as external, unforeseeable and unavoidable events beyond the reasonable control of the provider, in accordance with § 103 of the Võlaõigusseadus (Law of Obligations Act). These include, by way of illustration: natural disasters, armed conflicts, acts of public authorities, general failures in telecommunications infrastructures, massive cyberattacks and restrictions on access to underlying provider systems.

2.11. Modification of the conditions

BlueGo Solutions OÜ reserves the right to modify these terms. The version in force at any given time shall be the one published on the Site. Where a modification affects Consumer rights, it shall be notified with reasonable prior notice and, where appropriate, shall require new express acceptance before future purchases. Modifications shall not apply retroactively to orders already placed.

2.12. Suspension and termination

BlueGo Solutions OÜ may suspend, restrict or cancel access to the Platform, or cancel orders, in the following cases: (i) reasonable suspicion of fraud or abusive use of the Platform, coupons or the BlueCoins programme; (ii) non-payment or unjustified chargeback; (iii) material breach of these terms; (iv) requirement by a competent authority.

2.13. Assignment

The Customer may not assign the rights and obligations arising from the contract without the prior written consent of BlueGo Solutions OÜ. BlueGo Solutions OÜ may assign its contractual position in cases of corporate restructuring, merger, demerger or total or partial transfer of an economic unit, informing the Customer with reasonable advance notice and respecting any legally provided rights of objection.

2.14. Communications

Communications between the parties shall be made by electronic means, primarily email. The Customer must keep their contact address up to date. Notifications shall be deemed received at the time of their dispatch to the email address provided.

2.15. Partial nullity

Should any clause of these terms be declared null or ineffective, this shall not affect the validity of the remaining clauses, in accordance with § 31, paragraph 4, of the Võlaõigusseadus (Law of Obligations Act).

2.16. Applicable law and jurisdiction

These terms are governed by the law of the Republic of Estonia, with the express exclusion of the United Nations Convention on Contracts for the International Sale of Goods of 1980. For the resolution of any dispute, both parties submit to the jurisdiction of the Courts of Tartu (Tartu Maakohus), without prejudice to the Consumer's inalienable right to bring proceedings before the courts of their domicile or habitual residence in accordance with Regulation (EU) No 1215/2012 (Brussels I bis), and without prejudice also to the alternative dispute resolution mechanisms described in Section 10.

Specific Terms for the eSIM Service

Framework applicable to the acquisition of eSIM (Embedded SIM) profiles marketed by BlueGo Solutions OÜ as a reseller from selected third-party providers in the eSIM supply chain. This section supplements, but does not replace, the general terms (Section 02).

3.1. Nature of the service

The eSIM service consists of the provision of a preconfigured mobile virtual network operator (MVNO) profile, downloadable via QR code or remote activation, which enables the Customer's device to connect to mobile telecommunications networks in one or more countries. BlueGo Solutions OÜ acts as a reseller of third-party providers, in accordance with the indirect marketing regime permitted under the Elektroonilise side seadus (Electronic Communications Act) for non-operator resellers, in line with economic activity EMTAK 61201 registered in the Commercial Register.

BlueGo Solutions OÜ discretionally selects, and periodically reviews, a portfolio of third-party providers in the eSIM supply chain, in order to ensure the best combination of coverage, price and availability for each plan and destination. The specific identity of the provider supplying a particular profile does not constitute an essential element of the contract for purposes of its validity, without prejudice to the Customer's right to receive, upon request to customer service, reasonable information about the technical origin of the profile purchased, in compliance with the transparency principles of Article 6(1)(c) of Directive 2011/83/EU.

3.2. Device technical requirements

The use of the eSIM service requires a device compatible with eSIM technology (GSMA SGP.22), unlocked or without operator restrictions for secondary profiles. It is the Customer's sole responsibility to verify the compatibility of their device before placing an order. BlueGo Solutions OÜ publishes on the Site an indicative, non-exhaustive list of compatible devices.

3.3. Activation, validity and expiry

Once the QR code has been received, the Customer shall have a specified period, indicated in the product listing and in the confirmation email, to install and activate the eSIM profile. Installation initiates the plan validity period only when the first connection to the mobile network occurs, unless otherwise specifically indicated in the product listing.

Once activated, the plan has the contracted validity period and data volume. Once the data volume is exhausted or the validity period has expired, the profile will cease to provide service. Unconsumed data is neither cumulative nor refundable.

3.4. Coverage and quality of service

Coverage, connection speed and quality of service depend on the roaming agreements and the infrastructures of local mobile operators in each country. The information published on the Site regarding coverage and speeds is indicative and does not constitute a quality of service commitment. Occasional loss of coverage, speed variations or limitations imposed by the local operator shall not give rise to a right to a refund, without prejudice to the lack of conformity regime provided for in Directive (EU) 2019/770.

For plans that include coverage in the European Economic Area, Regulation (EU) 2022/612 on roaming on public mobile communications networks within the Union shall apply, particularly with regard to regulated wholesale prices and fair use policies.

3.5. Acceptable use

The Customer undertakes not to use the eSIM service for:

  • unlawful, fraudulent activities or activities harmful to the rights of third parties;
  • resale activities, commercial distribution or permanent use as a substitute for a local contract;
  • massive automated use, artificial traffic generation, sending unsolicited commercial communications or use of the service as a technical gateway for third-party infrastructures;
  • use that infringes the fair use policies defined by the underlying provider.

Non-compliance may result in the immediate suspension of the profile without right to a refund, without prejudice to any legal actions that may apply.

3.6. Refunds in case of non-activation

In accordance with the commercial policy published on the Site, BlueGo Solutions OÜ shall refund the amount paid where the Customer reliably demonstrates that the eSIM profile has not been installed or activated within the stipulated validity period and has not consumed any data. The request must be addressed to support@bluego.io. This commercial policy supplements, but does not replace, the Consumer's legal rights.

3.7. Underlying provider terms

Certain technical aspects of the service are additionally governed by the terms of the third-party provider that actually supplies the eSIM profile. The conditions applicable to the specific provider shall be delivered to the Customer, in a durable format, together with the purchase confirmation where such conditions contain specific obligations relevant to the Customer. In the event of a discrepancy between the terms of the underlying provider and these terms, the latter shall prevail to the extent that they are more favourable to the Consumer under applicable law.

3.8. Notice regarding eSIM and right of withdrawal

Pursuant to Article 16(1)(m) of Directive 2011/83/EU and § 53, paragraph 4, point 8, of the Võlaõigusseadus (Law of Obligations Act), the right of withdrawal is excluded in respect of digital content supplied on a non-tangible medium from the moment its download or performance begins, provided that the Consumer has given prior, express and informed consent to the loss of the right of withdrawal. Consequently, once the Customer installs the eSIM profile on their device (which constitutes the beginning of the performance of the digital content), the ordinary fourteen-day right of withdrawal ceases to be exercisable. This circumstance is communicated prominently during the payment process.

3.9. Unlimited plans: fair use

Our unlimited plans give you data with no fixed total allowance for normal, everyday personal use. To keep the network fair for everyone, once you use more than 3 GB in a day, we temporarily reduce your speed to 1 Mbps for the rest of that day, and your full speed automatically returns when your daily allowance resets (24 hours after you activate your eSIM).

These plans are designed for personal use by an individual traveller. Because of that, there is a point at which sustained, continuous usage goes so far beyond normal personal use that it indicates the connection is no longer being used in a personal way — for example, automated systems, servers, or large-scale connection sharing. If usage reaches that level, we may slow, suspend or stop the connection to protect the network and prevent misuse, in line with our Fair Use Policy.

Specific Terms for the Flight Compensation Product with AirHelp

Framework applicable to the purchase of the "Flight Compensation" product, provided by AirHelp Germany GmbH and marketed by BlueGo Solutions OÜ as a commercial intermediary. The product is configured as a passenger claims management service under Regulation (EC) No 261/2004, not as an insurance contract. Text drafted in accordance with Directive 2011/83/EU (consumer rights), Directive (EU) 2019/770 (digital content and digital services), Regulation (EC) No 261/2004 on air passenger rights and the Võlaõigusseadus (Law of Obligations Act) (Estonian law of obligations).

4.1. Nature of the product and provider

"Flight Compensation" is a passenger claims management service which, in the event of a cancellation or significant delay of a covered commercial flight, processes on the Customer's behalf the compensation claim against the airline in accordance with Regulation (EC) No 261/2004 and, where applicable, guarantees a payment to the Customer in accordance with the particular conditions of the service.

The product is provided by AirHelp Germany GmbH, a company domiciled at Kurfürstendamm 11, 10719 Berlin, Germany, registered in the Handelsregister of Berlin-Charlottenburg under number HRB 226753 B (hereinafter, "AirHelp"), in its capacity as the material provider and sole party responsible for the service vis-à-vis the Customer with regard to the scope, processing and payment of compensation.

BlueGo Solutions OÜ acts as a commercial intermediary that makes the product available to the Customer for purchase through the Platform, receiving therefor the remuneration described in clause 4.10. The involvement of BlueGo Solutions OÜ does not entail the provision, distribution, mediation, agency or operation of insurance activity or any other activity subject to financial authorisation; the product does not constitute an insurance contract for the purposes of the Kindlustustegevuse seadus (Insurance Activities Act), Directive 2009/138/EC (Solvency II) or Directive (EU) 2016/97 (IDD).

The Finantsinspektsioon (Estonian Financial Supervision Authority) has confirmed that the activity of BlueGo Solutions OÜ in relation to this product does not require registration or authorisation under the Estonian prudential financial regime, as there is no provision, mediation or distribution of an insurance contract. The substantive nature of the product is governed by Regulation (EC) No 261/2004 and by the particular conditions accepted with AirHelp.

The marketing of the product is governed, with respect to BlueGo Solutions OÜ, by:

  • Directive 2011/83/EU on consumer rights, in particular regarding pre-contractual information, contract formation and the right of withdrawal;
  • Directive (EU) 2019/2161 (the "Omnibus" Directive);
  • Directive (EU) 2019/770 on digital content and digital services;
  • Directive 2005/29/EC on unfair commercial practices, with regard to the truthfulness, clarity and non-misleading nature of product information;
  • the Võlaõigusseadus (Law of Obligations Act) (Estonian law of obligations).

The substantive regime of air passenger rights is governed by Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004 establishing common rules on compensation and assistance to passengers in the event of denied boarding and of cancellation or long delay of flights.

4.3. Product coverage

The Flight Compensation product provides the Customer, under the terms detailed by AirHelp in its particular conditions, with:

  • the management, on the Customer's behalf, of the compensation claim provided for by Regulation (EC) No 261/2004, which amounts, depending on the flight distance, to EUR 250, EUR 400 or EUR 600 per passenger;
  • where applicable, a lump-sum compensation from AirHelp regardless of the success of the claim against the airline, in accordance with the particular conditions of the service;
  • passenger assistance in matters of communication with the airline, collection of documentation and, where appropriate, the bringing of legal proceedings by AirHelp.

The exact scope, amounts and payment conditions are those published by AirHelp at any given time in the particular conditions of the product, which the Customer expressly accepts during the purchase process.

4.4. Eligible flights: admissibility rules

The product is purchased per individual flight. Only flights that, at the time of purchase, cumulatively meet the following three conditions, verified in real time by means of a query to an external aviation data API (Cloudflare Workers proxy), are eligible:

  1. Flight status: the flight must show a status of scheduled. Flights with a status of active, landed, cancelled, diverted or incident are rejected.
  2. Absence of reported delay: the departure delay field (departure.delay) must be null or zero.
  3. Minimum advance time: the scheduled departure (departure.scheduled) must be at least six (6) hours after the time of purchase.

If any of the three conditions is not met, the flight cannot be added to the product and the system will display the specific reason for the rejection. This limitation is intended to prevent abusive practices and to ensure the effective viability of the flight management, as an event that has already occurred or is imminent cannot be processed.

4.5. Price and billing

The price of the product is EUR 2.50 per flight, unless otherwise expressly communicated in the product listing at the time of purchase. The price is due in full at the time of payment of the order and is not pro-ratable.

4.6. Service information document

Prior to purchase, the Customer receives a concise information document on the product, drafted in clear and comprehensible language, in compliance with Articles 6 and 8 of Directive 2011/83/EU, describing:

  • the nature of the product as a claims management service;
  • the scope of the services and the indicative compensation amounts under Regulation (EC) No 261/2004;
  • the covered events and the excluded events;
  • the temporal duration of the product, linked to the specific flight;
  • the Customer's obligations to activate the service;
  • the claims procedure;
  • the identifying details of the material provider (AirHelp Germany GmbH);
  • the total price including taxes.

4.7. Claims procedure

In the event of cancellation or significant delay of the covered flight, the Customer must:

  1. access the customer panel or contact AirHelp through the channels provided;
  2. provide the documentation requested (boarding pass, airline communication, expense receipts, etc.);
  3. authorise, if required, AirHelp to act on their behalf vis-à-vis the airline.

The time limits, procedures and remedies applicable to the payment of compensation are governed by the particular conditions of the product communicated by AirHelp and by Regulation (EC) No 261/2004.

4.8. Exclusions

Excluded events include, among others, the circumstances set out in Article 5(3) of Regulation (EC) No 261/2004 (extraordinary circumstances not attributable to the airline), as well as those others expressly set out in the particular conditions of the product communicated by AirHelp.

4.9. Right of withdrawal for the Flight Compensation product

In accordance with Article 9 of Directive 2011/83/EU and § 56 of the Võlaõigusseadus (Law of Obligations Act), the Consumer may withdraw from the product, without penalty and without the need to state reasons, within fourteen (14) calendar days from the date of purchase, unless: (i) the covered flight has taken place before the expiry of said period; or (ii) the Customer has actively exercised any of the product's functionalities (for example, filing a claim through AirHelp), in which case the service is deemed to have commenced with the Customer's consent, in accordance with Article 16(1)(a) of Directive 2011/83/EU. In such cases, the right of withdrawal is extinguished.

4.10. Remuneration of the commercial intermediary and transparency

The remuneration of BlueGo Solutions OÜ for the marketing of the product consists of a commission included in the final price paid by the Customer, communicated transparently for the purposes of Article 6(1)(e) and (g) of Directive 2011/83/EU. The price shown to the Customer is the final total price they pay; no additional surcharges are applied for the involvement of BlueGo Solutions OÜ.

4.11. Processing of personal data in the context of Flight Compensation

The personal data provided by the Customer for the purchase and, where applicable, the processing of the product shall be communicated to AirHelp Germany GmbH, which shall act as an independent data controller with respect to those processing operations it carries out in fulfilment of the service provided to the Customer (in particular, the management of the claim against the airline), without prejudice to any joint controllership functions that may arise from duly documented joint operations. AirHelp's detailed privacy policy may be consulted at airhelp.com. The remainder of the privacy framework is set out in Section 07 of this document.

BlueCoins Loyalty Programme Terms

Rules applicable to the "BlueCoins" loyalty programme, implemented by BlueGo Solutions OÜ as a closed-loop mechanism to reward recurring customers. The programme is structured as a deferred discount on future purchases and, given its closed and non-monetary nature, falls outside the scope of Directive 2009/110/EC on electronic money and Directive (EU) 2015/2366 on payment services (PSD2).

BlueCoins are internal-use value units issued by BlueGo Solutions OÜ that entitle their holder to a discount on future purchases made on the Platform, under the terms of this document. BlueCoins:

  • are not a currency, electronic money, financial instrument or crypto-asset;
  • are not redeemable for cash, convertible into currency or transferable between customers;
  • do not constitute a monetary liability with market value, but rather a contractual promise of a discount subject to these terms;
  • may only be used within the BlueGo Platform, in accordance with the closed-loop scheme described in recital 6 of Directive 2009/110/EC.

BlueGo Solutions OÜ records the aggregate balance of BlueCoins in circulation as a non-monetary liability, with adequate coverage, ensuring at all times the effective possibility of redemption under these terms.

5.2. Earning BlueCoins

The registered Customer earns BlueCoins upon completing purchases on the Platform, subject to the following rules:

  • Earning ratio: 0.1 BlueCoin per EUR 1.00 of order subtotal, excluding Value Added Tax and excluding any amount paid through redemption of previously earned BlueCoins.
  • Base currency: the programme always operates in EUR. Any reference to another currency on the Site corresponds to the informational multi-currency converter described in Section 09.
  • Registered customers only: earning BlueCoins requires prior creation of a Customer account. Guest checkout purchases do not generate BlueCoins, without prejudice to the checkout page informatively displaying the amount that would have been earned had the Customer registered.
  • Anti-loop rule: the portion of the price paid through BlueCoins redemption is not eligible to generate new BlueCoins.

5.3. Batch expiry (FIFO)

Each batch of BlueCoins earned on a given order expires twelve (12) months from the date it was earned. Redemption follows the FIFO (First In, First Out) principle: the oldest BlueCoins are considered consumed first. Expired BlueCoins are automatically removed from the Customer's balance and are not recoverable.

The Customer will receive, at least thirty (30) calendar days in advance, an expiry notice by email, provided that failure to receive such notice for reasons beyond the control of BlueGo Solutions OÜ (for example, an outdated email address) shall not suspend the expiry.

5.4. Redeeming BlueCoins

Redemption is governed by the following conditions:

  • Redemption value: 1 BlueCoin equals EUR 1.00 discount on the order price.
  • Partial redemption: partial use of BlueCoins is permitted, including decimal amounts.
  • VAT unchanged: redemption reduces the order subtotal, and the applicable VAT is recalculated on the resulting taxable base, in accordance with Estonian and European Union tax rules.
  • Audit trail unchanged: every movement is recorded in an immutable ledger with Customer identification, base amount in EUR, reason and timestamp.

5.5. Manual allocation and corrections

BlueGo Solutions OÜ may manually allocate BlueCoins to a Customer as compensation, a goodwill gesture or for a justified reason. Any manual allocation must be accompanied by the corresponding reason in the movement ledger, in accordance with the principles of transparency and traceability.

5.6. Suspension, withdrawal and termination

BlueGo Solutions OÜ may suspend, withdraw or cancel earned BlueCoins, as well as close the Customer's account, where any of the following circumstances arise: (i) fraud or attempted fraud, system manipulation, programme abuse or use of coupons in unauthorised combinations; (ii) unjustified chargeback of the order that originated the batch; (iii) material breach of the general or specific terms. Suspension may be precautionary while the facts are being investigated.

5.7. Modification or discontinuation of the programme

BlueGo Solutions OÜ may modify the programme terms or discontinue it, notifying participating Customers by email with a minimum notice of thirty (30) calendar days. Discontinuation shall not affect BlueCoins already earned and not expired, which may be redeemed within their validity period. Modifications shall not retroactively prejudice Customers with respect to BlueCoins already earned.

5.8. Accounting and tax treatment

The accounting recognition and tax treatment of BlueCoins are carried out in accordance with Estonian law (Raamatupidamise seadus (Accounting Act)) and the applicable VAT rules (Käibemaksuseadus (VAT Act)). In particular, redemption is treated as a reduction of the order price, with VAT recalculated on the resulting taxable base, in line with the case law of the Court of Justice of the European Union on deferred discounts.

5.9. Complaints and enquiries

Any enquiry or complaint relating to the programme may be sent to support@bluego.io, including the Customer's identification and a description of the facts.

General Terms for Coupons and Promotional Codes

Terms applicable to promotional codes issued by BlueGo Solutions OÜ or by authorised third parties, whether in marketing campaigns, affiliate programmes, partnerships with commercial partners or as a loyalty gesture. This section applies on a general basis; the specific conditions of each campaign may clarify, extend or restrict these rules by express mention in the communication of the code.

6.1. Definition and issuance

A "coupon" or "promotional code" means any alphanumeric sequence which, when entered in the corresponding field during the checkout process, grants the Customer a discount, a free service, an ancillary benefit or other advantage defined in the campaign.

BlueGo Solutions OÜ may issue coupons unilaterally or in collaboration with partners. Issuance by third parties without express authorisation shall render the coupon invalid and may, where applicable, give rise to the appropriate legal actions.

6.2. Coupon characteristics

Each coupon is governed by the following attributes, which shall be published in the coupon communication:

  • Discount type: percentage of subtotal, fixed amount, free ancillary product, free plan upgrade or others.
  • Minimum order: minimum subtotal amount required to activate the coupon.
  • Per-Customer usage limit: maximum number of times the same Customer may apply the coupon.
  • Global usage limit: total number of redemptions permitted in the campaign.
  • Validity period: start and end dates of the promotion.
  • Geographical scope: countries or regions in which the coupon is admissible.
  • Eligible products: the specific catalogue to which it applies.
  • Compatibility: with other coupons, with BlueCoins redemption or with other promotions.

6.3. Combination rules

Unless expressly stated otherwise, coupons may not be combined with each other. Simultaneous use of a coupon with BlueCoins redemption is permitted, unless specifically restricted by the campaign; the order of application is: (i) application of the coupon to the subtotal; (ii) calculation of the new subtotal; (iii) application, if applicable, of BlueCoins redemption to that subtotal; (iv) calculation of VAT on the resulting taxable base.

6.4. Prohibitions

The following are expressly prohibited:

  • the assignment, sale or resale of coupons, unless the campaign itself permits it;
  • the use of coupons through automated procedures, bots or any techniques intended to circumvent usage limits;
  • the generation, distribution or use of counterfeit, expired or illegitimately communicated coupons;
  • the combination of coupons in a manner contrary to the published rules;
  • the use of coupons in a fraudulent manner or contrary to good faith.

6.5. Cancellation, revocation and modification

BlueGo Solutions OÜ reserves the right to cancel, revoke or modify any coupon, as well as to invalidate specific redemptions, in the following circumstances: (i) material error in the published conditions; (ii) detection of fraud or abuse; (iii) force majeure preventing the continuation of the campaign; (iv) requirement by a competent authority.

Orders already completed with a validly applied coupon shall not be retroactively affected, unless fraud or abuse in obtaining or using the coupon is established.

6.6. Non-monetary nature

Coupons are not redeemable for cash and are not transferable to a monetary balance. They do not constitute electronic money or a financial instrument. Their economic value is for internal use and is exhausted upon redemption or upon expiry of the validity period.

6.7. Commercial communications

The sending of coupons by email, SMS or other channels shall comply with the requirements of the GDPR and Directive 2002/58/EC (ePrivacy) as transposed in Estonia. The receipt of commercial communications requires the prior consent of the recipient or, where applicable, the existence of the "soft opt-in" exception under Article 13, paragraph 2, of Directive 2002/58/EC. The recipient may unsubscribe at any time, free of charge, through the procedure indicated in each communication.

Currency and Conversion Information

Mandatory information on the multi-currency display system and the actual billing currency, in accordance with the principles of clear and comprehensible information required by Directive 2011/83/EU and Directive 2005/29/EC on unfair commercial practices.

9.1. Base currency and billing currency

BlueGo Solutions OÜ sells all its products with a base price in euros (EUR). The actual billing currency for any order is always the euro. The conversion from the currency in which the Customer's card is charged to euros, where applicable, shall be carried out by the card-issuing institution or by the payment processor, in accordance with their own terms and with Regulation (EU) 2019/518 on transparency of conversion charges.

9.2. Multi-currency display

For informational convenience, the Site may display prices converted into other currencies: United States dollar (USD), pound sterling (GBP), Japanese yen (JPY), Chinese yuan offshore (CNY), Australian dollar (AUD) and Canadian dollar (CAD), among others that may be added.

This display is purely informational and indicative. The final charge will always be made in euros and the exact amount in the Customer's card currency will depend on the exchange rate applied by the card-issuing institution at the time of the charge, over which BlueGo Solutions OÜ has no control.

9.3. Exchange rate sources

The exchange rates used for the visual conversion are sourced from external providers, primarily the Frankfurter API (European Central Bank data) and, in the event of an incident, from equivalent alternative sources. Rates are updated daily and stored in the internal database. Minor differences between the displayed price and the final charge may occur due to latency between the update and the time of payment.

9.4. Geolocation for currency suggestion

BlueGo Solutions OÜ may automatically suggest the display currency based on the country from which the Site is accessed, identified through approximate IP address geolocation using the local MaxMind GeoLite2 database. This operation is performed entirely on BlueGo's server, without transmitting the User's IP address to MaxMind or any other third parties. The legal basis for this processing is the legitimate interest of BlueGo Solutions OÜ in providing the User with a transparent and comprehensible commercial experience (Article 6, paragraph 1, point (f), of the GDPR), an assessment documented in the corresponding Legitimate Interest Assessment (LIA), which may be consulted upon justified request.

If the User manually selects a currency, the choice is stored in the preferences cookie bluego_currency, described in Section 08. The maximum duration of this cookie is twelve (12) months.

9.6. Attribution

This product includes GeoLite2 data created by MaxMind, available at www.maxmind.com.

Right of Withdrawal, Refunds and Dispute Resolution

Mandatory information on the right of withdrawal, its exceptions, the complaints procedure and alternative dispute resolution mechanisms, in accordance with Directive 2011/83/EU, Directive (EU) 2019/2161, Regulation (EU) 524/2013 (ODR) and Directive 2013/11/EU (ADR).

10.1. Consumer's right of withdrawal

As a general rule, the Consumer who contracts at a distance with BlueGo Solutions OÜ shall have a period of fourteen (14) calendar days to withdraw from the contract, without giving any reason and without penalty, in accordance with Article 9 of Directive 2011/83/EU and § 56 of the Võlaõigusseadus (Law of Obligations Act).

10.1.1. Calculation of the period

The period shall begin to run:

  • in the case of contracts for services or digital content not supplied on a tangible medium, from the day the contract is concluded;
  • in the case of contracts for the sale of goods (not applicable to the core activity of BlueGo Solutions OÜ), from the day the Consumer receives the goods.

10.1.2. How to exercise the right

To exercise the right of withdrawal, the Consumer may:

  • use the model withdrawal form included in Annex I, Part B, of Directive 2011/83/EU, reproduced at the end of this Section;
  • or make an unequivocal statement of the decision to withdraw, by email to support@bluego.io, indicating the order details.

It shall be sufficient for the Consumer to send the withdrawal communication before the expiry of the period. The burden of proof regarding the exercise of the right within the time limit shall lie with the Consumer.

10.1.3. Effects of withdrawal

BlueGo Solutions OÜ shall reimburse all payments received from the Consumer, including, where applicable, delivery charges, within a maximum of fourteen (14) calendar days from receipt of the withdrawal declaration, using the same means of payment used by the Consumer for the original transaction, unless otherwise agreed and without any charge to the Consumer as a result of such reimbursement.

10.2. Exceptions to the right of withdrawal

Pursuant to Article 16 of Directive 2011/83/EU and § 53, paragraph 4, of the Võlaõigusseadus (Law of Obligations Act), the right of withdrawal does not apply to:

  • Digital content not supplied on a tangible medium (Article 16.1.m): where performance has begun with the Consumer's prior express consent and the Consumer has acknowledged the loss of the right of withdrawal. This is the case for an eSIM profile once installed or activated, as well as for the delivery of the QR code where its use has commenced.
  • Services whose performance has begun, with the Consumer's prior express consent, and the Consumer has acknowledged that the right would be lost once the service has been fully performed (Article 16.1.a).
  • Other cases under Article 16 that may be applicable depending on the nature of the service.

Without prejudice to the right of withdrawal, the Consumer has the legal guarantee of conformity provided for in Articles 11 et seq. of Directive (EU) 2019/770 and in Chapter 11 of the Võlaõigusseadus (Law of Obligations Act), for a minimum period of two (2) years from the delivery of the digital content or digital service, subject to the specific rules applicable to continuous services.

10.4. Complaints

The Customer may submit complaints by email to support@bluego.io. BlueGo Solutions OÜ shall acknowledge receipt within a maximum of five (5) business days and shall resolve the complaint within a maximum of thirty (30) calendar days, except in duly justified cases of complexity.

10.5. Alternative and online dispute resolution

In accordance with Regulation (EU) 524/2013 on online dispute resolution, the Consumer may use the European online dispute resolution platform, available at https://ec.europa.eu/consumers/odr.

Additionally, in accordance with Directive 2013/11/EU, the Consumer may submit a complaint to the Tarbijavaidluste Komisjon (Estonian Consumer Disputes Committee), under the Tarbijakaitse ja Tehnilise Järelevalve Amet (TTJA), located at Endla 10A, 10122 Tallinn, Estonia, accessible at komisjon.ee. BlueGo Solutions OÜ undertakes to participate in good faith in proceedings initiated before this Committee where required to do so.

10.6. Judicial remedies

Without prejudice to extrajudicial remedies, the Consumer may have recourse to the competent courts, in accordance with the applicable rules on international and national jurisdiction, including the inalienable right to bring proceedings at the place of domicile or habitual residence provided for in Regulation (EU) No 1215/2012.

10.7. Model withdrawal form

(Complete and return this form only if you wish to withdraw from the contract.)

To BlueGo Solutions OÜ, Tartu mnt 67/1-13b, 10115 Tallinn, Estonia — support@bluego.io:

I hereby give notice that I withdraw from my contract for the provision of the following service: ________________________________________

Ordered on / received on (*): ___ / ___ / ______

Name of the Consumer: ________________________________________

Address of the Consumer: ________________________________________

Signature of the Consumer (only if this form is submitted on paper): ________________________________________

Date: ___ / ___ / ______

(*) Delete as appropriate.

Version 1.1 · September 2026

BlueGo Solutions OÜ — Registrikood 17482859 — EE102989498 — Tartu mnt 67/1-13b, 10115 Tallinn, Estonia.

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