GENERAL TERMS AND CONDITIONS — CARNET & CARNINJA

GENERAL TERMS AND CONDITIONS — CARNET & CARNINJA (ENGLISH)

Updated 02/11/2026

Hebel & Margo BV

1. Identity of the Provider

Carnet & CarNinja are trade names of:

Hebel & Margo BV Kapellekensweg 32, 3391 Meensel-Kiezegem, Belgium

Company number: 0794.199.079

VAT number: BE 0794.199.079

E-mail: info@carnet.be

Carnet functions as an online marketplace where individuals and professional traders can publish and sell vehicles. Carnet is not a party to any sales transaction between users. As an online marketplace, Carnet complies with the obligations under the Digital Services Act (DSA), including traceability of traders and transparency.

2. Scope of Application

These General Terms and Conditions apply to:

• All visits to and use of Carnet.be

• Use of CarNinja

• The placement, management, and removal of advertisements

• The use of features, AI-supported descriptions and image processing, AI sales and purchase advice (CarNinja)

• Communication between users via the platform

• All services offered by Carnet to individuals or traders

By using Carnet, the user declares agreement with these terms. Users must be at least 18 years old or have permission from a parent/guardian (for compliance with WER and DSA).

3. Services Provided by Carnet

Carnet offers:

1. A platform for publishing vehicle advertisements

2. Tools to edit or optimize photos

3. AI-based descriptions and text suggestions (such as AI co-pilot, CarNinja, and purchase/sales advisor)

4. A marketplace for individuals and dealers

5. Optional premium services or promotions for professional garages

On the marketplace, Carnet brings buyers and sellers together. In the service "An offer for your car" (Article 8bis), Carnet acts as an intermediary between the seller and the dealer who makes the offer; the sale is concluded between those two. Carnet reserves the right, where applicable, to buy or sell a vehicle itself; this is then stated expressly in the sales agreement. Carnet is not an inspection authority. For each advertisement, we inform users whether the seller is a professional (with consumer rights under WER) or an individual. Ranking of advertisements is based on relevance, date, and paid promotions (transparency in accordance with DSA Art. 31). There are no additional transaction costs via the platform, but users are responsible for their own external costs (e.g., taxes). Carnet proactively checks advertisements for illegal content (duty of care DSA).

4. User Categories

4.1 Individuals

• May place a maximum of 2 free advertisements per year

• Advertisements must include vehicles of which they are the owner or authorized owner

• Abuse (such as commercial publications) may lead to removal

4.2 Professional Traders

• Advertisements are paid, unless Carnet applies a temporary promotion

• Carnet may change conditions, prices, and promotions at any time (with 15 days prior notice and right of termination, in accordance with DSA Art. 14 and WER)

• Professional sellers must comply with Belgian consumer legislation (WER Book VI)

• For traceability (DSA Art. 30 - KYBC): Professional traders must verify their identity before publication by providing name, address, phone, e-mail, identity document, bank account details, company number, and self-certification of compliance with EU law. Carnet may, if deemed necessary, verify this data via official databases (e.g., KBO, VAT register) and stores it for the duration of the relationship + 6 months. Incomplete information may lead to refusal/suspension. Name, physical address, e-mail address, and phone number of car garages (professionals) are publicly displayed in advertisements.

5. Placement of Advertisements

An advertisement must:

• Contain correct and complete information

• Not be misleading

• Not include stolen vehicles, damaged vehicles, or prohibited content

• Contain own photos or photos for which the user has rights

Carnet may refuse or remove advertisements that:

• Are misleading or incorrect

• Violate legislation

• Are obviously fraudulent

• Harm the quality of the platform

• Contain technical errors

Upon removal, the user receives a motivated explanation (in accordance with DSA Art. 20). Users can complain or object via the internal mechanism (see Art. 16).

6. Editing of Images and AI Descriptions

The user expressly grants Carnet permission to:

• Edit, optimize, or crop photos

• Add watermarks

• Generate AI descriptions via own algorithms and third parties (such as OpenAI, Gemini, or other AI models)

• Process metadata, including EXIF data

The user confirms that: • AI descriptions are informative and generated by AI (transparency in accordance with AI Act Art. 50: "This is an AI tool; interaction is with AI, not with a human, and may contain errors or biases")

• Errors may occur; users remain responsible for accuracy

• Carnet bears no liability for AI generation or interpretation.

• For AI co-pilot and advisors: We conduct risk assessments and ensure human oversight for critical advice (AI Act compliance); additional obligations apply for high-risk AI.

7. Duration of Advertisements

Advertisements remain online:

• As long as the user wishes

• Until the vehicle is sold

• Until Carnet removes the advertisement due to abuse or non-compliance

Users are responsible for timely removal of sold vehicles.

8. Costs for the seller

Asking for an offer and having the car offered on the Carnet auction costs the seller nothing. The amount Carnet tells the seller, through our systems or by phone, goes entirely to the seller: no costs are deducted from it. Carnet charges its costs to the dealer who buys the car.

8bis. An offer for your car and the Carnet auction (added on 14 October 2026, amended on 2 November 2026)

Besides the marketplace, Carnet offers the service "An offer for your car":

• The seller asks for an offer free of charge and without obligation. Carnet shows the car anonymously to dealers and buyers, through a personal link and, after Carnet's review, on the Carnet auction.

• The Carnet auction is only open to professional car dealers that Carnet checks beforehand (including their VAT number). Carnet may refuse or withdraw access.

• Offers go through Carnet. The amount the seller sees or hears is paid to the seller in full (see Article 8).

• For the seller, an offer is without obligation: the seller is only bound once a written sales agreement is signed. If the seller accepts an offer, the seller sells the car to the dealer who made that offer. The sales agreement is concluded between the seller and that dealer; Carnet acts as an intermediary and is not a party to that agreement, unless Carnet itself acts as the buyer (Article 3).

• The dealer pays the purchase price directly to the seller, in the manner and at the time set out in the sales agreement. Carnet does not receive or hold any funds on behalf of the seller and charges its costs to the dealer (Article 8).

• The seller gives correct details about the car. If the seller changes the brand, model or year, Carnet informs anyone who already made an offer.

• Carnet may refuse a request or an offer, take it off the auction or delete it, for example in case of incorrect details or abuse.

For dealers who make an offer

• Every offer is a guaranteed offer: whoever makes an offer commits to buying the car at that amount.

• The seller guarantees that the car is as described. If it is, the offer is binding and the buyer can no longer negotiate the price at collection.

• The buyer collects the car directly from the seller within 7 days, unless agreed otherwise. Any other agreement is stated in the sales agreement.

• If the car is not as described, the buyer may, as provided by law, make an adjusted offer or refuse the purchase.

9. Behavioral Rules

Users may not use the platform for:

• Fraud, deception, or illegal vehicle trade

• Publishing others' data or photos without permission

• Spamming other users

• Commercial trade under an individual account

• Manipulating price information

• Abusing AI functions

Carnet may restrict, suspend, or remove accounts in case of abuse, with motivation.

10. Limitation of Liability

Carnet is not liable for:

• Errors or inaccuracies in advertisements

• Disputes between buyer and seller

• Hidden defects of vehicles

• Damage, loss, lost profits, or costs

Except in case of intent, gross negligence, or breach of essential obligations (not excluded in accordance with WER unfair terms). Carnet provides no guarantees on:

• The condition of vehicles

• The accuracy of information

• The reliability of users

• Professional sellers can place vehicle advertisements themselves but authorize Carnet automatically to import advertisements – manually, via API or software – from their own dealer website. Carnet will always notify the seller as soon as the import is live. The seller retains access to check and adjust info. Imported data complies with Belgian legislation, incl. mandatory mentions from WER Book VI and the Law of 11 June 2004. For sales to end customers: seller draws up a written agreement with full vehicle description. Buyer checks conformity themselves (incl. options) before signing. In accordance with WER art. VI.64-74: seller remains responsible for conformity, but buyer has due diligence and is also responsible for checking the vehicle against the description before paying or signing a sales agreement.

The platform is "as is" and "as available." In case of technical disruptions, we strive for quick recovery. The platform complies with the Web Accessibility Directive for accessibility.

11. Intellectual Property

• The user retains copyrights on their photos

• The user grants Carnet a non-exclusive, revocable license to use photos and texts for publication, marketing, optimization, and AI improvement (duration: as long as needed for the service, max. 6 months after removal)

• Carnet owns all rights to the platform, AI algorithms, generated descriptions, image editing tools, layout, structure, and trade names

12. Processing of Personal Data

Carnet processes personal data in accordance with the Privacy Policy of Hebel & Margo BV, available via carnet.be/privacy. Carnet follows GDPR rules, including the right to access, deletion, rectification, and objection. Data is processed for account management, advertisements, fraud prevention, analysis, improvement, and marketing (with consent).

• Carnet may, in accordance with our Privacy Policy, share contact details of private users with verified professional sellers (garages) if the platform detects that the private individual is interested in a specific vehicle model and the garage has it in stock. Conversely, garage details may be shared with private individuals if Carnet determines that the garage best matches the vehicle they are seeking. This is done solely to facilitate relevant offers, in compliance with GDPR.

13. Termination of Accounts

Carnet may terminate an account for:

• Abuse

• Fraud

• Breach of terms

• Repeated complaints

• Incorrect data

• Publication of prohibited content

 • Attempt to manipulate the platform

With motivation and right to complain. Users may delete their account at any time.

14. Changes to Services and Terms

Carnet may change the platform, add/remove features, adjust terms, or change prices for traders. Changes are announced at least 15 days in advance via e-mail or platform. Users have the right to terminate without costs in case of substantial changes (in accordance with DSA and WER).

15. Applicable Law

These terms are exclusively governed by Belgian law. In case of disputes, only the court of the Vlaams-Brabant district is competent.

16. Complaints Mechanism and Dispute Resolution (DSA Art. 20-21)

Users can submit free complaints via info@carnet.be regarding decisions (e.g., ad removal, suspension). Complaints are handled within 14 days with human review, max. 30 days for complexity. If unresolved: access to certified out-of-court bodies. Annual transparency reports on moderation are available on the site.

17. Payments and Withdrawal (WER Book VI)

For paid services: Payment methods (e.g., Bancontact, credit card), incl. VAT for individuals; excl. VAT for professionals. Professional users have a 14-day withdrawal right for distance services, with refunds.

Withdrawal Information: You have the right to withdraw from the contract within a period of 14 days without giving reasons. The withdrawal period expires 14 days after the day on which the contract is concluded (e.g., payment for premium services). To exercise the right of withdrawal, you must inform us (Hebel & Margo BV, Kapellekensweg 32, 3391 Meensel-Kiezegem, Belgium, E-mail: info@carnet.be, Phone: 0493677895) by means of an unambiguous statement (e.g., in writing by post, fax, or e-mail) of your decision to withdraw from the contract. You may use the attached model withdrawal form for this, but it is not obligatory. To comply with the withdrawal period, it is sufficient to send your communication concerning your exercise of the right of withdrawal before the withdrawal period has expired.

Consequences of Withdrawal: If you withdraw from the contract, you will receive all payments you have made up to that point, including delivery costs (except for any additional costs resulting from your choice of a delivery method other than the cheapest standard delivery offered by us), without delay and in any event no later than 14 days after we have been informed of your decision to withdraw from the contract. We will reimburse you using the same means of payment as you used for the original transaction, unless you have expressly agreed otherwise; in any case, no costs will be charged to you for such reimbursement. If you have requested that the services commence during the withdrawal period, you will pay us an amount proportional to what has been provided to you up to the time you notify us of the withdrawal, compared to the full scope of the contract.

Exceptions: The right of withdrawal does not exist for contracts regarding the supply of digital content not supplied on a tangible medium if performance has begun with your express prior consent and you have acknowledged that you thereby lose your right of withdrawal.

Model Withdrawal Form: (Fill in and return this form only if you wish to withdraw from the contract.)

• To Hebel & Margo BV, Kapellekensweg 32, 3391 Meensel-Kiezegem, Belgium, E-mail: info@carnet.be:

• I/We () hereby give notice that I/We () withdraw from my/our () contract of sale of the following goods/provision of the following service ()

• Ordered on ()/received on ()

• Name of consumer(s)

• Address of consumer(s)

• Signature of consumer(s) (only if this form is notified on paper)

• Date (*)

• Invoicing via e-invoice (PEPPOL-compliant from 2026 for B2B).

18. Force Majeure

Carnet is not liable in case of force majeure (e.g., natural disasters, cyberattacks) that prevent service provision.

19. Severability

If a provision is invalid, the remaining provisions remain in full force. The parties undertake to replace the invalid provision with a valid one that most closely approximates the economic purpose.