How to read these Terms. These Terms of Service govern access to and use of the Twelve platform and all purchases made through it. They form a binding agreement between you and Mentortain S.R.L. Defined terms are explained in Section 3. If you do not agree with these Terms, please do not use Twelve.
Part I — The Platform and the Contract
1. Who we are
1.1. Twelve is operated by Mentortain S.R.L., a limited liability company registered in Romania, with registered office at Sat Bucov, Comuna Bucov, Strada Dacia nr. 78, Județul Prahova, Romania, Trade Register no. J29/396/2024, sole registration code (CUI) 49569212, EUID ROONRC.J29/396/2024, email help@twelve-app.com (“Twelve”, “we”, “us”, “our”). Mentortain S.R.L. is not registered for VAT purposes in Romania at the date of these Terms (small-enterprise exemption regime, art. 310 of the Romanian Fiscal Code); Section 9.6 explains what this means for prices and fees.
1.2. Twelve is a mobile platform for the health, nutrition, fitness and wellness sector where Creators publish short-form video and sell services, mini-courses (“Series”) and community subscriptions, and where Users discover, purchase and consume them.
1.3. Twelve is a video-sharing platform service within the meaning of the Romanian Audiovisual Law no. 504/2002, as amended by Law no. 190/2022, under the jurisdiction of Romania and notified to the National Audiovisual Council (CNA). Section 17 sets out what this means.
2. The contract structure — please read this first
Twelve operates through two commercial tracks, and the contracting parties differ between them.
2.1. Track A — Services (processed by Stripe)
Track A covers coaching, consultations, personalised plans, paid direct messages, one-to-one audio or video calls, and freelance-style deliverables.
When a User purchases a Service, the sale contract is concluded between the User and Twelve. Twelve sells the Service in its own name and issues the purchase document (invoice or receipt) to the User in Twelve’s name. The Service itself is performed by the Creator, who supplies it to Twelve under the Creator supply terms in Section 8 and Annex B. For Romanian VAT purposes this operates as the structură de comisionar under art. 271 para. (2) of the Fiscal Code: Twelve is deemed to receive the Service from the Creator and to supply it onward to the User.
What this means for Users: your contractual counterparty, your invoice, your refund and your consumer rights under Sections 10 and 11 run against Twelve. What it does not mean: Twelve does not itself coach, advise or treat anyone; does not direct or supervise how a Creator performs; does not assume responsibility for a Creator’s qualifications (Section 6); and gives no guarantee of any outcome. The Creator remains fully and personally responsible for the professional content and performance of the Service (Sections 7.6 and 21, and Annex A).
2.2. Track B — Series and Subscriptions (processed by Apple / Google)
Mini-courses (“Series”) and recurring subscriptions to a Creator’s community or premium content are purchased exclusively through Apple In-App Purchase or Google Play Billing. Apple or Google is the merchant of record for those purchases: it contracts with the buyer, collects payment, applies its own commission, and handles consumer tax. Twelve receives the net proceeds remitted by the store, retains its fee, and credits the Creator (Section 9.2). Refunds for Track B purchases are governed by the policies of Apple or Google (Section 10.6).
2.3. The Platform Agreement
Independently of any purchase, these Terms govern every user’s access to and use of Twelve, including accounts, content, conduct and moderation.
2.4. Creators are independent
Creators are independent professionals or businesses. Nothing in these Terms creates any employment, agency, partnership or joint-venture relationship between a Creator and Twelve. Creators set their own prices (within store constraints on Track B), methods, schedule and clientele.
3. Definitions
Creator — a user who publishes content or sells on Twelve.
User — a user who consumes content or purchases on Twelve; a user may be both a Creator and a User.
Expert Creator — a Creator holding the activity-based platform status described in Section 6.5.
Service — a Track A offering.
Series — a pre-recorded mini-course sold as a one-off purchase (Track B).
Subscription — recurring paid access to a Creator’s community or premium content (Track B).
Order — a purchase of a Service, including via a Custom Offer.
Custom Offer — a bespoke scope and price offered by a Creator to a specific User in chat.
Base Price — the price a Creator sets for a Service, before the Buyer Service Fee and the Order Processing Fee.
Buyer Service Fee — 6% added on top of the Base Price and paid by the User (Section 9.1).
Order Processing Fee — the payment-processing charge paid by the User on Track A purchases (Section 9.1).
Creator Service Fee — the fee Twelve retains from Creator earnings — 6% on Track A; 12% on Track B.
Net Store Proceeds — the amount Apple or Google actually remits to Twelve for a Track B sale, after the store’s commission and adjustments.
Creator Balance — cleared earnings awaiting payout.
Payout Costs — the payment-processor charges associated with paying a Creator, described in Section 9.3, borne by the Creator.
Deliverable — any work product delivered by a Creator under an Order.
Part II — Accounts and Eligibility
4. Age — 18+
4.1. Twelve is for adults only. You must be at least 18 years old to create an account or to use Twelve in any capacity. The application carries an 18+ age rating on the App Store and on Google Play.
4.2. We apply proportionate age-assurance measures (including declared date of birth and store-level age signals) and terminate accounts we reasonably believe belong to persons under 18. Access control is Twelve’s primary measure for the protection of minors under the Audiovisual Law and the Digital Services Act. Suspected under-age accounts may be reported in-app or at help@twelve-app.com.
5. Accounts
5.1. You must provide accurate, complete registration information and keep it current. Only one account per person is permitted. You must not create accounts to evade enforcement, or to manipulate referrals, reviews, levels or leaderboards.
5.2. You are responsible for all activity under your account and for the security of your credentials. Report any suspected compromise to help@twelve-app.com.
5.3. Where you act as a Creator, you are a “business user” for the purposes of Regulation (EU) 2019/1150 (the “P2B Regulation”), and Twelve applies the P2B safeguards set out in these Terms (notice periods, ranking transparency, complaints and mediation) to all Creators. Where you purchase as a consumer, mandatory consumer-protection law prevails over anything in these Terms.
6. Creator onboarding — no verification of qualifications
6.1. To sell on Twelve, a Creator must: (a) be at least 18 years old; (b) complete identity verification through Stripe Connect (Section 9.3); (c) provide the information required by Sections 6.3 and 9.7; and (d) accept Annex A (Community & Health Content Standards) and Annex B (Self-Billing & Payment Documentation Mandate).
6.2. Twelve does not assume any responsibility for Creators’ qualifications, diplomas, certifications, experience or professional status. Like other open content platforms, Twelve hosts content and offerings from Creators of all backgrounds. Nothing on Twelve — including any badge, level, ranking or verification mark — is a statement by Twelve that a Creator is qualified, licensed or competent. Users are responsible for evaluating a Creator before purchasing, and Section 21 (Health and Safety) applies to everything on the platform.
6.3. Creator warranty and trader information. Each Creator warrants that they comply with every law applicable to them and to what they offer, including any licensing or registration requirement in any jurisdiction they target. Creators selling Services must supply the trader information required by arts. 30–31 of Regulation (EU) 2022/2065 (legal name, address, contact and identification details, payment account, and trade or fiscal registration where it exists) and a self-certification that they will offer only services compliant with applicable law. This is an information and self-declaration requirement; it is not, and must not be presented as, a qualification check by Twelve.
6.4. Prohibited service categories. Regardless of any qualification a Creator may hold, the following may not be offered on Twelve at all: medical acts of any kind; the diagnosis, treatment or management of disease; the prescription or recommendation of prescription-only medicines; psychotherapy or clinical psychological services; and remote clinical care. Listings framed as any of the above are removed. General coaching, education, training, lifestyle and habit services remain permitted, subject to Annex A.
6.5. Expert Creator badge. “Expert Creator” is an activity-based platform status earned through on-platform metrics and peer-recommendation votes. It reflects platform engagement and community standing only. It is not a professional credential, licence or endorsement, and the product displays it with that clarification. It may be withdrawn where the criteria lapse or were gamed.
6.6. Levels and statuses. Creator levels, User skill levels, and the Pioneer, Ambassador and Founder referral statuses confer recognition and feature access only. They carry no monetary value, are non-transferable, and may be modified or withdrawn where criteria are not met or were gamed.
Part III — Buying and Selling
7. Track A — Services
7.1. Listing. The Creator defines the scope, Base Price, delivery time, revision allowance and package tiers. Listings must be accurate and must comply with Annex A. The listing, together with the Order requirements, defines the Deliverable.
7.2. Ordering. The User pays the Base Price, plus the 6% Buyer Service Fee, plus the Order Processing Fee (Section 9.1), at checkout and in advance, via Stripe. The funds are held by our payment processor and are not released to the Creator until the Order is completed and the clearance period has elapsed (Section 9). By placing an Order you authorise us and our payment processor to charge your payment method for the full amount, and to obtain a pre-authorisation (which may appear as a temporary “hold” on your card or account) where the payment method requires it.
7.3. Order lifecycle. Created → Paid → Requirements submitted → In progress → Delivered → Completed. The delivery clock starts when the User submits requirements. Delivery takes place through the platform. The User may accept, request an in-scope revision, or open a dispute. Orders auto-complete 72 hours after delivery if the User takes no action; auto-completion does not extinguish consumer rights or the dispute window in Section 11.
7.4. Custom Offers made in chat create an Order on the offered terms, with identical fees, escrow and dispute rules.
7.5. Cancellation before delivery may occur by mutual agreement, or by Twelve where the Creator is unresponsive past the delivery deadline; the User receives a full refund of the Base Price, the Buyer Service Fee and the Order Processing Fee.
7.6. Creator performance duties. Creators must deliver what was offered, on time. Repeated cancellations, lateness, unresponsiveness or dispute losses affect ranking (Section 15), levels and selling rights.
8. Creator supply and remuneration (Track A)
8.1. By listing a Service, the Creator agrees to supply it to Twelve for resale to the User under Section 2.1. The Creator’s remuneration for each completed Order is 94% of the Base Price (that is, the Base Price minus the 6% Creator Service Fee), less the Payout Costs described in Section 9.3.
8.2. The Creator authorises Twelve to conclude the sale with the User in Twelve’s name, to collect payment, to issue the User-facing purchase document, and to handle User-facing refunds under Sections 10 and 11, with corresponding adjustment of the Creator’s remuneration.
8.3. Invoicing between the Creator and Twelve is handled without any action by the Creator, under the Self-Billing & Payment Documentation Mandate in Annex B.
9. Fees, payouts, invoicing and tax
9.1. Track A fees (Services)
| Component | Rate | Borne by | Applied to |
|---|---|---|---|
| Buyer Service Fee | 6% | User | on top of the Base Price |
| Order Processing Fee | cost + 20% | User | payment processing (see below) |
| Creator Service Fee | 6% | Creator | retained from the Base Price |
Order Processing Fee. The cost of payment processing on Track A is borne by the User through an Order Processing Fee, displayed at checkout before payment. The Order Processing Fee is set to recover Twelve’s payment-processing costs for Twelve’s services plus a handling margin of 20% (that is, processing cost plus 20%). It is applied uniformly, as a single platform fee, regardless of the payment method or card used — it is a platform charge, not a payment-instrument surcharge, consistent with the prohibition on card surcharging for consumer payments in the EU/EEA (art. 62(4) of Directive (EU) 2015/2366, transposed in Romania by Law no. 209/2019). It is refunded together with the rest of the payment on full refunds, and pro rata on partial refunds.
Worked example — Base Price 100, illustrative processing cost 3: the User pays 100 (Base Price) + 6.00 (Buyer Service Fee) + 3.60 (Order Processing Fee = 3 × 1.20) = 109.60. The Creator is credited 94.00 (100 minus the 6% Creator Service Fee), less the Payout Costs in Section 9.3.
9.2. Track B fees (Series and Subscriptions)
| Component | Rate | Borne by | Applied to |
|---|---|---|---|
| Store commission | Apple / Google rate (typically 15–30%) | buyer (via the in-app price) | gross in-app price |
| Creator Service Fee | 12% | Creator | Net Store Proceeds |
The Creator is credited 88% of the Net Store Proceeds, less the Payout Costs in Section 9.3. The price the buyer pays in-app is final and inclusive of the store’s commission, so the store’s cost is economically borne by the buyer through the listed price. Creators set in-app prices from the store’s available price points and are advised to set them taking the store commission and Twelve’s fee into account; the dashboard shows the resulting net before publishing. Store rates, currency conversion and tax handling are set by Apple or Google, not by Twelve.
Worked examples — in-app price 100: at a 30% store rate, Net Store Proceeds are 70.00 and the Creator is credited 61.60 (before Payout Costs); at a 15% rate (small-business store programmes), Net Store Proceeds are 85.00 and the Creator is credited 74.80 (before Payout Costs). No Buyer Service Fee and no Order Processing Fee apply on Track B.
9.3. Payouts and Payout Costs — Stripe
Payouts run automatically on the 1st and 15th of each month to the Creator’s Stripe Connect Express account, for all cleared balances of at least USD 10; smaller balances roll forward. Stripe onboarding supports both individuals (no registered business required) and companies; the account type is selected during Stripe onboarding and cannot be changed afterwards.
Payout Costs are borne by the Creator. The Payout Costs charged by the payment processor in connection with paying a Creator are deducted from the payout or from the Creator Balance. These include the per-payout fee, the monthly active-account fee (a fixed amount charged by Stripe for each connected account that receives a payout in a given month), the cross-border payout fee where applicable (currently 0.25% of the payout, waived within the EEA/UK), and currency-conversion costs where the Creator’s account is in a currency other than the platform currency. The current amounts are always shown in the Creator dashboard before the Creator lists anything for sale, and the net amount payable to the Creator is shown before each payout.
Payout coverage. Payouts are available only in the countries supported by Stripe for Twelve’s platform region (at the date of these Terms: the United States, the United Kingdom, the European Economic Area, Canada and Switzerland; the current list is shown in the dashboard). Creators in unsupported countries cannot receive payouts and should not list paid offerings until support is added. Twelve may add further payout rails or countries over time.
Currency. The platform currency is USD: Base Prices, Creator Balances and statements are denominated in USD. Where the Creator’s bank account is in another currency, Stripe converts at payout at its prevailing rate, with conversion costs borne by the Creator as part of the Payout Costs.
9.4. Clearance. Track A earnings clear 14 days after the Order reaches Completed status (the refund and chargeback window), after which they join the Creator Balance.
9.5. Set-off, withholding and limits. We may set off against the Creator Balance any refund, chargeback, reversal, penalty or amount owed for breach, and may withhold payouts during fraud or safety investigations, or while the information required by Section 9.7 is missing. Where the Creator Balance is insufficient to cover an amount owed, the shortfall remains due and we may recover it from subsequent earnings or by other lawful means. To prevent financial loss to you, to other users or to Twelve, we may also delay a payout, impose or adjust a limit on the amount a Creator may earn or receive over a given period, or restrict access to payment features, acting reasonably and for no longer than necessary.
9.6. VAT status of Twelve. Mentortain S.R.L. currently applies the small-enterprise VAT exemption (art. 310 of the Fiscal Code): prices and fees do not include Romanian VAT and no VAT is shown on purchase documents. If and when Twelve becomes VAT-registered, VAT will be applied where legally due and displayed at checkout, and any resulting change follows the notice rules in Section 20.
9.7. DAC7. Twelve is a reporting platform operator under Directive (EU) 2021/514 (DAC7), transposed in Romania by Government Ordinance no. 16/2023. We collect and report annually to ANAF prescribed information about Creators (identity, tax identification number, financial account identifier, consideration paid per quarter, and fees charged). Where a Creator fails to supply the required information after our initial request and two reminders, and 60 days have passed since the initial request, we are required by law to either close the account or withhold payment of the Creator Balance until the Creator complies, and we will do so.
9.8. Creator taxes. Creators are solely responsible for registering, declaring and paying their own taxes and social contributions on their Twelve earnings in every relevant jurisdiction. Twelve withholds nothing unless legally required, and provides no tax advice.
9.9. Purchase documents. Twelve issues Track A purchase documents electronically, in Twelve’s name, and reports invoices through the RO e-Factura system where required by Romanian law. Track B purchase documents are issued by Apple or Google.
9.10. Status of funds and payment services. Twelve is not a bank, a payment institution, an electronic money institution or a money transmitter, and does not provide regulated payment services. Twelve does not hold, safeguard or take custody of user funds: all payments are collected, held and settled by our payment processors — Stripe for Track A, and Apple or Google for Track B — acting under their own terms and their own regulatory authorisations. Amounts shown in your Creator Balance are an accounting record of what is owed to you under these Terms; they are not a deposit, do not bear interest, and are not covered by any deposit-guarantee or investor-compensation scheme. Because the service Twelve provides is intermediation rather than a regulated payment service, the specific consumer protections that apply to regulated payment services under the applicable payment-services framework (for example, the statutory regime for unauthorised transactions or the safeguarding of funds) do not arise against Twelve in respect of that service; your rights against the payment processor under its own terms, and your statutory consumer rights against Twelve as seller of record under Sections 10 and 11, are unaffected.
Relationship with processor terms. By transacting on Twelve you also accept the applicable terms of the relevant payment processor. Those terms govern your relationship with that processor — including its own settlement timing, fees, reserves, chargeback and dispute rules — and prevail in the event of conflict in respect of that relationship. These Terms govern your relationship with Twelve. Twelve is not responsible for acts or omissions of a payment processor, and where a processor suspends, restricts or terminates a Creator’s account, Twelve may be unable to pay out until the Creator resolves the matter with that processor.
9.11. Dormant balances. Where a Creator Balance remains below the payout threshold and the account has been inactive for 24 consecutive months, we will attempt to contact the Creator at the email address on file. If we receive no response within 90 days of that contact, and where the account has been closed or deleted leaving an unpaid balance, we will deal with the balance in accordance with applicable law, including by remitting it to the competent authority where the law so requires. We do not forfeit balances that are lawfully owed to a Creator merely because of inactivity, and a Creator may claim a dormant balance at any time before it is remitted under this Section.
10. Consumer withdrawal and Track B refunds
10.1. Track A (Services). Consumers in the EU generally have 14 days to withdraw from a distance contract (Government Emergency Ordinance no. 34/2014), subject to the statutory carve-outs: (a) where full performance has begun at the consumer’s express request and the Service is fully performed, the right lapses, provided the consumer gave prior express consent and acknowledged loss of the right; (b) where the consumer withdraws mid-performance, they are charged proportionally for what was supplied; (c) digital content supplied immediately, with the consumer’s consent and acknowledgement, loses the right upon supply; and (d) fully bespoke Deliverables made to the consumer’s specification may fall under the personalisation exemption. Checkout collects the required consents.
10.2. Conformity. Because Twelve is the Track A seller of record, statutory conformity remedies for consumers (Government Emergency Ordinance no. 141/2021 for digital content and services) run against Twelve. Twelve has full recourse against the Creator whose non-performance caused the remedy (set-off under Section 9.5; indemnity under Section 22.6).
10.3. Refund mechanics (Track A). Full refunds return the Base Price, the Buyer Service Fee and the Order Processing Fee to the original payment method. Partial refunds are pro-rated, including the Buyer Service Fee and the Order Processing Fee.
10.4. Chargebacks. Initiating a card chargeback in bad faith instead of using the process in Section 11 may lead to account suspension; the disputed amount and any processor fee are recoverable from the responsible party.
10.5. Subscriptions (Track B) renew automatically until cancelled in the User’s Apple or Google account settings; cancellation takes effect at the end of the current billing period.
10.6. Track B refunds are requested from and decided by Apple or Google under their policies. Twelve will assist where it can but cannot compel a store refund. Where a store refund or clawback occurs, the corresponding Creator credit is reversed.
11. Disputes between Users and Creators (Track A)
11.1. The sequence is: (1) direct resolution in the Order thread; (2) an in-scope revision; (3) escalation to Twelve within 14 days of delivery; and (4) Twelve’s review of the listing, the requirements, the Order thread and the Deliverable, resulting in a decision to uphold the Order, order a partial refund, or order a full refund, with reasons.
11.2. Twelve’s dispute decision is an administrative decision about the release of funds held for the Order and about the parties’ platform accounts. It does not adjudicate legal rights and does not bar either party from pursuing legal remedies; consumers’ statutory rights are unaffected.
11.3. Frivolous or bad-faith disputes, and delivery extortion through dispute or review threats (in either direction), breach these Terms.
Part IV — Content and Conduct
12. Content rules
12.1. All content — videos, listings, Series, community posts, direct messages and reviews — must comply with Annex A (Community & Health Content Standards).
12.2. Audio and music. Twelve provides no licensed music library. You may upload only audio you own or have licensed for commercial use on Twelve. Unlicensed commercial music is removed; repeat infringement leads to termination (Section 19.5).
12.3. AI content. AI-generated or AI-edited content that realistically depicts people, bodies, results or events must be clearly labelled as AI-generated. Presenting AI output as a real client result, a real transformation, or a professional clinical assessment is prohibited.
12.4. Commercial communications — mandatory declaration. Twelve provides an in-product control for declaring that a video or post contains advertising, sponsorship, product placement or other audiovisual commercial communication, as required of video-sharing platforms by the Audiovisual Law. Creators must use it whenever applicable (“Paid partnership” / “Ad”) and remain responsible for advertising-law compliance in their target markets. Supplement and weight-management product promotion is further restricted by Annex A.
12.5. User data received by Creators. A Creator who receives User personal data (including health data) in order to perform a Service acts as an independent controller: they must use it only to perform the Service, keep it secure, not retain it beyond need, and never disclose it or use it for marketing. A Creator Data Annex applies.
13. Prohibited conduct
(a) Integrity — fake engagement; bought or bartered reviews; manipulation of levels, leaderboards, referrals or ranking; multiple or impersonation accounts; scraping or systematic extraction; interference with or unauthorised access to systems; and circumventing moderation, age or geographic controls.
(b) Commerce — misrepresenting identity, qualifications, results or affiliations; fabricated transformations or testimonials; and listing what you cannot lawfully or practically deliver.
(c) Circumvention — soliciting or making payment for a Twelve-originating transaction off-platform. This applies to relationships originated on Twelve; it does not restrict a Creator’s pre-existing clients or independent business and does not require exclusivity. Requesting contact details in order to circumvent counts as circumvention.
(d) Communication — harassment, threats, hate speech or discriminatory abuse; spam and unsolicited bulk messaging; and sharing another user’s personal data.
(e) Safety — any sexual content involving minors (zero tolerance; reported to authorities); sexual solicitation; and breaches of Annex A.
(f) Sanctions and restricted jurisdictions — using Twelve, or receiving payouts through it, in connection with any person, entity, territory or activity subject to economic or trade sanctions or export controls imposed by the European Union, the United Nations, the United States or any other applicable authority. You warrant that you are not a sanctioned person and are not acting on behalf of one. We may screen users and transactions against sanctions lists as required by law and may block, freeze, delay or refuse a transaction or payout, and suspend or terminate an account, where required to comply with sanctions or where we have reasonable grounds to suspect a breach. Where funds are frozen or a payout is blocked under this provision, we may be legally prevented from releasing them or from explaining the reason in detail.
14. Reviews
Only a User who completed a paid Order may review it, reflecting genuine experience. Incentivised, traded or coerced reviews are prohibited in both directions. Purchase-verified reviews are labelled, in accordance with Directive (EU) 2019/2161. We remove reviews that are unlawful, unrelated, or contain personal data — but not merely because they are negative.
15. Ranking and recommender transparency
This Section is provided in accordance with art. 5 of the P2B Regulation and art. 27 of the Digital Services Act.
15.1. Main parameters. In the personalised feed: interest match (stated interests and viewing behaviour), engagement quality (completion rate, watch time, saves), a recency allowance for new content, safety and compliance status, and the Annex A content class. In Marketplace search: query and category match, fulfilment performance (on-time rate, cancellation rate, dispute rate), review score and volume (recency-weighted), price fit, and safety and compliance status. Content classified Feed-Ineligible under Annex A is excluded from recommendation surfaces but may remain searchable; accounts that repeatedly post such content may be made temporarily ineligible for recommendation, with notice and appeal.
15.2. Controls. Users can manage their interests and use “not interested” controls to influence their feed; these are the modification options provided under art. 27 of the Digital Services Act.
15.3. No paid ranking exists at the date of these Terms. If it is introduced, it will be clearly labelled and announced with 15 days’ notice. Twelve’s own editorial content (for example, Twelve Magazine) is labelled and does not rank within Creator Marketplace results.
15.4. Main parameters are disclosed; the underlying algorithms and weights are trade secrets protected under Directive (EU) 2016/943.
16. Moderation, enforcement and appeals
This Section is provided in accordance with Regulation (EU) 2022/2065 (the Digital Services Act).
16.1. Notice and action. Anyone may report content in-app or at help@twelve-app.com. We confirm receipt, act on valid notices, and inform the notifier of the decision and available redress.
16.2. Measures. We may remove or restrict content; make content or accounts ineligible for recommendation; suspend monetisation or selling rights; and suspend or terminate accounts. Automated detection is assisted by human review; no appeal is decided solely by automated means.
16.3. Statement of reasons accompanies every restriction (the facts, the provision applied, and redress options).
16.4. Enforcement ladder. Warning → removal → feed ineligibility (time-boxed, account-level) → monetisation or selling suspension → temporary account suspension → termination. Zero-tolerance breaches — minor sexual safety, credible threats, sale of dangerous substances, and severe fraud — skip the ladder, resulting in termination and, where applicable, referral to the authorities.
16.5. Appeals may be lodged within 6 months at help@twelve-app.com, and are reviewed by a person not involved in the original decision. Unresolved moderation disputes may be referred to a certified out-of-court dispute settlement body under art. 21 of the Digital Services Act. Our point of contact for these matters is help@twelve-app.com.
17. Audiovisual regulation (CNA) — video-sharing platform status
17.1. Twelve is a video-sharing platform service under Law no. 504/2002 (as amended by Law no. 190/2022) and has notified the National Audiovisual Council (CNA) prior to launch, as required by art. 74¹. Activity may begin no earlier than 10 days after the notification is filed.
17.2. As a video-sharing platform, Twelve maintains: measures protecting minors from content that may impair their development (the 18+ access model in Section 4 being the primary measure); measures protecting the general public from content inciting violence or hatred and from content whose dissemination is a criminal offence; the commercial-communication declaration control in Section 12.4; transparent reporting and complaint mechanisms (Section 16); and media-literacy measures.
17.3. Twelve cooperates with the CNA within the law, including — where legally required — providing the contact data of a user whose posted material breaches the Audiovisual Law.
17.4. Creator awareness. Romania-based Creators whose activity qualifies as an on-demand audiovisual media service under CNA rules may have their own notification or compliance duties toward the CNA. Those duties belong to the Creator; Twelve may surface information about them but does not assume them.
18. Creator suspension and termination — P2B safeguards
18.1. Where we restrict or suspend a Creator’s selling, we provide a statement of reasons on a durable medium at or before the time the measure takes effect. Where we terminate the whole relationship, we provide 30 days’ prior notice with reasons — except where the law requires immediate action, a zero-tolerance breach has occurred, or repeated breaches justify immediacy (in which case we state which exception we rely on).
18.2. On termination: open Orders are cancelled and Users refunded (or completed at the Creator’s election where Twelve permits); cleared balances are paid at the next scheduled run, subject to Sections 9.5 and 9.7; and User licences to already-purchased content survive (Section 19.4).
19. Intellectual property
19.1. Twelve’s marks, applications, design, software and databases belong to Twelve or its licensors.
19.2. Creators keep ownership of their content and grant Twelve a worldwide, non-exclusive, royalty-free, sublicensable (to hosting and processing providers) licence to host, store, reproduce, transcode, adapt for display, index, transcribe, tag, excerpt and display it, in order to operate, secure and improve Twelve and to promote Twelve and the Creator’s presence on it. This licence does not permit Twelve to sell Creator content, to license it to third parties as standalone content, or to use it in paid advertising creative without separate consent.
19.3. AI. Twelve applies automated processing to content (transcription, tagging, quiz generation, moderation and recommendation). Twelve does not use Creator content to train general-purpose generative AI models. Any change to this position requires notice under Section 20 and, where material, consent.
19.4. User licences. Track A Deliverables are licensed for personal, non-transferable, non-commercial use unless the listing grants more. Series and Subscription content is licensed for personal viewing only; no recording, sharing or resale is permitted. Subscription access lasts while the subscription is active; purchased Series remain accessible while listed and for 12 months after delisting.
19.5. IP complaints may be sent to help@twelve-app.com (identifying the work, its location, your contact details and a good-faith statement). Repeat infringers are terminated.
19.6. Feedback may be used without restriction or compensation.
Part V — Changes, Health, Liability and General
20. Changes to these Terms
For Creators, we give at least 15 days’ notice on a durable medium before a change takes effect (and longer where the change requires technical adaptation); changes do not apply retroactively; the Creator may terminate before the change takes effect; and the notice period may be waived expressly. For consumers, changes are notified before taking effect and do not affect completed purchases. Immediate changes are made only where required by law or by an acute safety risk, in which case we state the ground relied on.
The version of these Terms in force at the moment you confirm a transaction governs that transaction.
21. Health and safety
21.1. Nothing on Twelve is medical advice, diagnosis or treatment, and no interaction on Twelve creates a clinical relationship. Consult a physician before beginning any diet, exercise, fasting, supplementation or recovery programme — especially if you have a medical condition, are pregnant or breastfeeding, are taking medication, have a history of an eating disorder, or are recovering from injury.
21.2. Twelve is not an emergency service. In an emergency, contact your local emergency number. If you are struggling with concerns about body image, food or exercise, support from qualified professionals and national helplines is available.
21.3. The health rules in Annex A are contractual obligations for all users, and breaching them is a material breach of these Terms.
21.4. AI-generated features (transcripts, tags, quizzes and skill levels) measure engagement, may be inaccurate, and are neither health guidance nor qualifications.
22. Liability
22.1. The platform is provided “as is” and “as available”; we do not warrant uninterrupted or error-free operation.
22.2. Twelve gives no warranty as to any Creator’s content, qualifications or conduct (Section 6.2) and no guarantee of any health, fitness or business outcome.
22.3. For Creators and business users: to the maximum extent permitted by law, Twelve is not liable for indirect or consequential loss, or for lost profit, revenue, data or goodwill; and Twelve’s aggregate liability is capped at the fees Twelve retained from that Creator in the 12 months preceding the claim.
22.4. For consumers: nothing in these Terms limits or excludes liability that cannot lawfully be limited, including liability for death or personal injury caused by negligence, for fraud, or under mandatory consumer-protection and conformity rules. Consumer statutory rights prevail.
22.5. Twelve is not liable for harm arising from following Creator content or programmes, except to the extent the harm results from Twelve’s own failure to act on a specific notice under Section 16.1 or 21 within a reasonable time, or as mandatory law otherwise provides.
22.6. Creator indemnity. Creators indemnify Twelve against claims, refunds, remedies, penalties and reasonable costs arising from their content, their Services, their credential misrepresentations, their intellectual-property or data breaches, or their tax non-compliance. This Section does not apply to consumers.
23. Data protection
Twelve processes personal data as controller in accordance with its Privacy Policy; health-related data receives the enhanced safeguards required for special-category data under art. 9 GDPR. In accordance with art. 9 of the P2B Regulation, Creators have access, through their dashboard and export functions, to their own listing, order, earnings, review and aggregate-audience data; Creators do not receive other Creators’ data, or User personal data beyond what is necessary to deliver an Order.
24. Creator complaints and mediation
This Section is provided in accordance with arts. 11 and 12 of the P2B Regulation.
24.1. Internal complaint-handling. Creators may submit complaints free of charge at help@twelve-app.com or through the in-app complaints form. We acknowledge complaints within 5 business days, examine them individually, and communicate a reasoned outcome ordinarily within 30 days. We publish annual aggregate information on complaint volume, subject matter, handling time and outcomes.
24.2. Mediation. Where a complaint is not resolved internally, Twelve is willing to engage in good faith with either of the following mediators to attempt an out-of-court settlement of platform-to-business disputes:
- Centrul de Mediere din cadrul Camerei de Comerț și Industrie a Municipiului București (Mediation Centre of the Bucharest Chamber of Commerce and Industry), Bucharest, Romania — a commercial mediation centre established in 2009 under Law no. 192/2006, handling domestic and international business disputes. Contact via ccib.ro.
- Jurimed — Centru de consultanță și mediere (Jurimed Mediation Centre), Bucharest, Romania — a mediation centre whose authorised mediators handle civil, commercial and intellectual-property disputes. Contact via jurimed.ro.
Both mediators are authorised under Romanian Law no. 192/2006 and listed in the official register held by the Consiliul de Mediere, and are selected to meet the criteria of art. 12(2) of the P2B Regulation: they are impartial and independent, affordable, able to conduct mediation in English and remotely, available without undue delay, and sufficiently familiar with platform-to-business commercial relations. Each party bears a reasonable share of the mediation costs as determined by the mediator. Engaging in mediation does not prejudice either party’s right to bring court proceedings.
24.3. Consumers. Romanian consumers may contact the National Authority for Consumer Protection (ANPC, anpc.ro) or use alternative dispute resolution under Law no. 140/2017.
25. General
Governing law — These Terms are governed by Romanian law; consumers resident in another EU member state retain the protection of the mandatory provisions of their country of residence.
Jurisdiction — The courts of Bucharest, Romania, have jurisdiction, save that a consumer may bring proceedings in, and may only be sued in, the courts of their place of residence.
Other terms — Users may not assign these Terms; Twelve may assign them in connection with a corporate reorganisation, on notice. These Terms are the entire agreement on their subject matter; if a provision is unenforceable, the remainder stands; and a failure to enforce is not a waiver. Neither party is liable for failure caused by an event beyond its reasonable control (excluding payment obligations). We may give notice in-app, in your dashboard, or by email to your registered address; a notice given electronically is deemed received 24 hours after it is sent or posted, and a notice sent by post is deemed received three business days after posting. Notices to us go to help@twelve-app.com and to the registered office in Section 1.1. Sections 9.5, 9.7–9.11, 10, 19, 22, 23 and 25 survive termination.
Annex A — Community & Health Content Standards
These standards apply to all content and listings and form part of these Terms. They use a four-class system adapted for a monetised health and fitness marketplace. Fuller illustrated standards are published separately (see Community & Health Content Standards); this Annex prevails in the event of conflict.
Class 1 — Prohibited
Disordered eating and dangerous weight loss. Showing, describing, promoting or glorifying — or offering, selling or requesting coaching for — disordered eating or dangerous weight-loss behaviours (on Twelve this covers listings, Series and Subscriptions, not only videos). This includes extreme low-calorie diets; starvation, bingeing and purging; body-checking and body-comparison trends; exercising through serious injury or illness; and the misuse of medication or supplements for weight loss or muscle gain. It also includes weight-loss product marketing: guaranteed or time-bound results, before-and-after imagery tied to a product, personal stories crediting a product, “detox” or “fat-burner” mechanisms, and comparisons to GLP-1 medication or equivalents.
Substances. The promotion, sale, or dosing instruction for anabolic steroids, SARMs, peptides, hormones, prescription-only medicines, or unapproved substances.
Medical claims. Claims to diagnose, cure, treat, mitigate or prevent disease; discouraging medical care or prescribed treatment; guaranteed health outcomes; and AI output presented as clinical assessment.
Universal. Sexual content involving minors (zero tolerance; reported to the authorities); sexual solicitation; credible threats or incitement; dangerous challenges likely to cause significant injury; fraud; and doxxing.
Class 2 — Restricted
Permitted on this adults-only platform, with additional friction: weight-management programmes and services (caloric targets, deficits, cutting or bulking protocols), permitted only when framed around health and carrying the Class 4 disclaimers, and subject to automated policy screening at upload or listing (flagged items may be held for human review before publication); body-transformation challenges; supplement-focused content within the Class 1 limits; structured fasting protocols; and cosmetic-procedure content, which must carry risk warnings.
Class 3 — Feed-Ineligible
Not recommended, but searchable; repeated posting can make an account temporarily ineligible for recommendation: before-and-after body imagery even without product ties; idealised-body promotion tied to weight management; borderline sensational health claims pending review; and content under active moderation review.
Class 4 — Allowed (with conditions)
General fitness, strength, mobility, nutrition education, healthy habits, sleep, stress and recovery; sports and event preparation (for example marathon or competitive bodybuilding) not framed as extreme weight loss; religious fasting in its cultural context; and condemning disordered eating without depicting methods. Any programme, plan or protocol must include an accurate disclosure of qualifications (or their absence) and a “not medical advice — consult a physician” notice, and must represent results honestly (typical, not exceptional).
Enforcement
Warning → removal → feed ineligibility → monetisation or selling suspension → temporary suspension → termination. Zero-tolerance items skip the ladder. All measures carry a statement of reasons and a right of appeal (Section 16).
Annex B — Self-Billing & Payment Documentation Mandate
This Annex is the prior agreement required by art. 319 para. (18) of the Romanian Fiscal Code and its methodological norms (point 96), and applies to every Creator upon acceptance of these Terms.
B.1. Mandate. The Creator appoints Twelve to issue, in the Creator’s name and on the Creator’s behalf, the invoices and/or payment statements documenting the Creator’s supplies to Twelve under Section 8 (Track A) and Section 9.2 (Track B). The Creator never issues an invoice to Twelve, and payouts are never conditional on the Creator issuing one.
B.2. Documents issued. (a) For Creators who are registered businesses (SRL, PFA, or foreign equivalents): a self-billed invoice per payout period, in the Creator’s name, containing the elements required by art. 319 para. (20)/(21) of the Fiscal Code, delivered via the dashboard and — for Creators established in Romania — reported by Twelve as issuer through RO e-Factura in accordance with applicable rules; the Creator records it in its own sales records. (b) For Creators who are natural persons without a registered business: a payment statement per payout period (identifying the parties, the period, the sales, and the gross amounts, fees and net paid), which together with these Terms constitutes the documentary basis of the payment and of Twelve’s expense records. The statement is not a fiscal invoice; the Creator remains responsible for declaring the income under their own national rules (in Romania, via the declarația unică regime, as applicable).
B.3. Acceptance. Each self-billed document is deemed accepted by the Creator unless the Creator objects, with reasons, within 10 days of it being made available in the dashboard. Objections are handled through the Section 24.1 complaints process; manifest errors are corrected by a corrective document.
B.4. Numbering and records. Twelve allocates a dedicated document series per Creator, maintains the audit trail linking each document to the underlying Orders and payouts, and provides permanent dashboard access and export.
B.5. Scope. This mandate does not prevent the Creator from issuing its own invoices for matters outside these Terms, and survives termination only for periods already elapsed.
B.6. Information duty. The Creator warrants the accuracy of the identification and tax data provided under Sections 6.3 and 9.7 and must update any change without delay; documents issued on the basis of the data on file are validly issued.