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ADVERTISING AND TERMS OF ADVERTISING SERVICES OF "RCA TELEGRAM NEWS CALIFORNIA"
0. Advertising: general information
"RCA TELEGRAM NEWS CALIFORNIA" offers advertising opportunities within its digital publication, subject to availability, the agreed campaign specifications and these terms. Services may include display advertising, clearly identified advertising features, sponsored content, video, contextual placements and other expressly agreed formats. Each proposal must identify the services offered, the publication channels, the campaign period, the price and the applicable measurement arrangements. Audience estimates and campaign forecasts must be distinguished from guaranteed deliverables. Advertising expenditure does not purchase editorial influence, favorable independent reporting or the suppression of legitimate journalism. The advertising supplier and the client’s contracting party is SCANDIC TRUST GROUP LLC, a limited liability company incorporated under Ukrainian law, registration number 1010351020000018952. SCANDIC ASSETS FZCO provides technical operation and administration within the scope of its appointment. LEGIER Beteiligungs mbH acts as an authorized payment recipient and advertising contact as described in section 8.1. Technical support or receipt of payment does not, by itself, transfer the supplier’s contractual obligations to either company.
Advertising inquiries
Publication contact: [email protected]
0.1. Legal requirements for advertising
Advertising must comply with the laws applicable to its content, audience, distribution and commercial purpose. Campaigns directed at California must satisfy applicable California and federal requirements. Distribution into other jurisdictions may create additional obligations that must be considered when the campaign is agreed. The client must identify the advertiser, the products or services promoted, the intended audience, the relevant territories and any regulated activity involved. The client must provide accurate campaign information and the evidence reasonably needed to assess compliance. The supplier remains responsible for its own conduct and for duties imposed directly upon it. Approval by the advertiser, an agency or the supplier does not constitute regulatory approval or make an otherwise unlawful advertisement permissible.
Identification of advertising and editorial independence
Advertisements must be readily recognizable as advertising where their commercial nature would otherwise be unclear. Advertising features, native advertising, sponsored articles, affiliate promotions and paid endorsements must carry clear and conspicuous disclosures appropriate to their presentation, such as "Advertisement", "Paid Advertisement" or "Sponsored Advertising Content". The disclosure must appear where readers need it to understand the commercial nature of the material, including before engagement where an editorial-looking headline, image or preview could otherwise mislead. A disclosure hidden in a footer, available only after following a link or contradicted by the overall presentation is insufficient. Material sponsorship, commissions, gifts, ownership interests or other commercial connections must be disclosed where required. Necessary disclosures must remain effective on mobile devices, in video and audio, and when the advertisement is republished or distributed through another agreed channel. Independent editorial decisions remain with the publication. Paid content must not falsely imply that an advertiser has received an independent editorial recommendation.
Accuracy, substantiation, testimonials and reviews
Advertising must not mislead through express statements, implications, imagery, omissions, selective comparisons or its overall impression. The advertiser must possess appropriate substantiation for objective claims before publication. The evidence required depends on the claim, the product and the relevant audience; health and safety claims generally require competent and reliable scientific evidence. Qualifications must be understandable, timely and sufficiently prominent, and must not contradict the principal claim. Testimonials must reflect genuine experiences and must not communicate claims the advertiser could not substantiate directly. Exceptional results must not be presented as generally expected results without adequate substantiation and disclosure. Fake reviews, fabricated expert endorsements, concealed material relationships, purchases of reviews conditioned on positive or negative sentiment, deceptive review suppression and misleading indicators of social influence are prohibited where covered by applicable law. Reviews must not be edited, selected or organized to create a materially false impression. These requirements include the Federal Trade Commission’s Rule on the Use of Consumer Reviews and Testimonials, 16 C.F.R. Part 465. Lawful negative reviews must not be suppressed through prohibited contractual restrictions or unfounded threats.
Prices, comparisons and promotional offers
Consumer-facing prices must comply with applicable price-transparency requirements, including California Civil Code section 1770(a)(29). Where that provision applies, an advertised or listed price must include mandatory fees and charges other than exclusions expressly permitted by law. An unavoidable processing or administration fee must not be concealed until checkout. Optional extras must remain genuinely optional. Discounts, former prices, savings, scarcity claims and promotional deadlines must be accurate and substantiated. Comparative advertising must not misrepresent a competitor’s products, prices, performance, affiliation or endorsement, including under section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), and California’s unfair competition and false advertising laws. Sweepstakes, contests and prize promotions must disclose material eligibility requirements, entry conditions, deadlines and restrictions, and must not constitute an unlawful lottery or prohibited gambling arrangement. A "free" offer must not conceal an unavoidable payment obligation. Advertisements for subscriptions, trials or recurring services must provide the disclosures and consent arrangements required by the California Automatic Renewal Law and the Restore Online Shoppers’ Confidence Act where those laws apply. A prominent claim cannot be cured by a contradictory or inconspicuous qualification.
Dignity, discrimination and responsible presentation
Advertising must comply with applicable civil rights, privacy and nondiscrimination requirements. Housing, employment, credit and public-accommodation advertisements must not communicate unlawful preferences, exclusions or limitations. These requirements include the Fair Housing Act, applicable federal employment and credit laws, the California Fair Employment and Housing Act and the Unruh Civil Rights Act within their respective scope. Unlawful discrimination must not be implemented indirectly through audience selection, exclusion criteria, inferred characteristics or delivery systems. A lawful geographic or audience restriction must have an appropriate basis and must not serve as a prohibited proxy. The supplier may also apply disclosed editorial standards concerning abusive, degrading, sexually explicit or gratuitously violent advertising. Those contractual standards do not imply that every offensive statement is unlawful. Advertising must not exploit serious vulnerability through deception, coercion or materially misleading claims.
Environmental and sustainability claims
Environmental claims must be specific, substantiated and proportionate to the benefit established. Broad claims such as "green", "eco-friendly", "sustainable", "carbon neutral" or "net zero" must not convey an environmental benefit that the advertiser cannot support. Material limitations, relevant trade-offs, the boundaries of the claim and reliance on carbon offsets must be explained where necessary to avoid deception. A claim about one product feature must not misleadingly describe an entire product, business or supply chain. Certifications and environmental seals must accurately identify what has been assessed and must not conceal material relationships with the certifying organization. The Federal Trade Commission’s Green Guides, 16 C.F.R. Part 260, provide relevant interpretive guidance. California’s Voluntary Carbon Market Disclosures Act, California Health and Safety Code sections 44475–44475.3, imposes additional website disclosure requirements on covered offset activities and specified emissions claims. A claim requiring supporting disclosures must not be published without the necessary information being available.
Political advertising and campaign transparency
Political advertising requires identification of the person or committee paying for the advertisement, the person authorizing it where relevant, its intended territorial reach and the election, candidate or ballot measure concerned. Federal requirements include applicable provisions of the Federal Election Campaign Act and Federal Election Commission regulations, including 52 U.S.C. § 30120 and 11 C.F.R. § 110.11. California campaign advertising must comply with the Political Reform Act, including the applicable disclosure provisions in Government Code sections 84501–84511, and other relevant election laws. Required payer, authorization and contributor disclosures must use the content, placement and presentation prescribed for the particular advertisement. The additional rules for an "online platform disclosed advertisement" apply only where the statutory definition and conditions are satisfied. Applicable records, reporting and restrictions concerning financing, coordination and foreign participation must also be observed. The supplier’s foreign incorporation does not remove these requirements. Any political advertising arrangement must be structured as a lawful commercial service and must not involve a prohibited foreign contribution, subsidy, extension of credit or participation in election-related decision-making. The supplier may require supporting documentation before acceptance. Independent news reporting and editorial commentary are assessed separately from paid political promotion.
Children and young people
Campaign design, placement and targeting must take account of the audience’s age, understanding and vulnerability. Advertising must not use deception to exploit children’s inexperience or conceal a commercial message that the intended audience would not reasonably understand. Age-restricted products require appropriate audience controls and compliance with product-specific restrictions; a statement that an advertisement is intended for adults is insufficient if its actual distribution violates the law. California Business and Professions Code section 22580 imposes additional restrictions on marketing specified products to minors where its conditions apply. The Children’s Online Privacy Protection Act and its implementing rule, 16 C.F.R. Part 312, govern covered collection and use of personal information from children under 13. Required verifiable parental consent, including separate consent for covered third-party disclosures used for targeted advertising, must be obtained where applicable. The California Consumer Privacy Act imposes separate authorization requirements for the sale or sharing of personal information concerning consumers known to be under 16, with parental or guardian authorization required for children under 13. These different thresholds must not be treated as a single general advertising age limit.
Food, alcohol, tobacco, vaping, nicotine and cannabis products
Food and dietary-supplement advertising must comply with applicable Federal Trade Commission and Food and Drug Administration requirements. Nutrition, health and disease-related claims require appropriate substantiation and must not misrepresent a product’s legal status, approved uses or therapeutic effects. Alcohol, tobacco, vaping and nicotine advertising must satisfy applicable federal and California restrictions, licensing requirements, product-specific warnings and protections against marketing to underage audiences. The legality of online publication must be assessed for the particular product and format. Cannabis advertising requires separate assessment under applicable California and federal law. Where California Business and Professions Code section 26151 and the Department of Cannabis Control’s advertising regulations apply, placements require reliable, current audience-composition evidence showing that at least 71.6% of the expected audience is 21 or older, together with the applicable license identification, content restrictions and other disclosures. Required direct-communication age checks and product-specific warnings must also be observed. A state license does not establish compliance with every federal requirement or authorize distribution into another jurisdiction. The supplier may decline a campaign if lawful placement cannot be established.
Gambling, medicines and financial promotions
Gambling advertising may be accepted only where both the promoted activity and its advertising are lawful for the intended audience and territory. An offshore license does not establish permission to solicit California residents. California Penal Code section 337o prohibits the defined online sweepstakes games and prohibits specified persons, including media affiliates, from knowingly and willfully supporting their operation, conduct or promotion. The statutory definition and exceptions must be assessed rather than treating every lawful promotional contest as prohibited gambling. Medicines and medical claims must comply with the Federal Food, Drug, and Cosmetic Act, applicable Food and Drug Administration regulations and relevant California law. Direct-to-consumer prescription-drug advertising is subject to specific requirements, including appropriate risk information, fair balance and applicable presentation rules; it is not subject to a general prohibition merely because it addresses the public. Financial, investment and digital-asset advertising must satisfy the requirements applicable to the product, activity and advertiser, including registration, licensing, exemptions, risk disclosures and antifraud rules. Where section 17(b) of the Securities Act of 1933, 15 U.S.C. § 77q(b), applies to paid securities publicity, the required compensation disclosures must be made; a generic "sponsored" label is not necessarily sufficient. California’s Digital Financial Assets Law must also be considered for covered activities, including the licensing requirements operative from July 1, 2026, and any lawful exemption or transitional status. A pending application must not be presented as an issued license. No advertisement may falsely imply government approval, guaranteed returns or insurance protection that does not apply.
Personal information, advertising technology and targeting
Advertising technology and audience targeting must comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act, its implementing regulations and other applicable privacy laws. The parties must identify their actual roles and responsibilities; calling a recipient a service provider or contractor does not establish that status unless the relevant legal conditions and contractual restrictions are met. Cookies, pixels, device identifiers, customer lists, matched audiences, retargeting and cross-context behavioral advertising require appropriate disclosures and any legally required consent or opt-out arrangements. Covered businesses must honor applicable sale and sharing opt-outs, including qualifying opt-out preference signals such as Global Privacy Control. Sensitive personal information must receive the protections required by law. Acceptance of an advertising contract does not authorize unrestricted disclosure of reader information or override an individual’s privacy choices. Hashing an identifier does not necessarily make it anonymous. Unapproved tracking, concealed recipient changes and attempts to circumvent a valid opt-out are prohibited. Client access to campaign reports does not automatically include access to identifiable audience information.
Electronic direct marketing
Commercial email must comply with the CAN-SPAM Act, 15 U.S.C. §§ 7701–7713, and other applicable requirements. Covered messages must use accurate sender information and nondeceptive subject lines, include the required identification and valid postal address, and provide a clear, effective opt-out mechanism. Valid opt-out requests must be honored within the applicable period, including the federal maximum of ten business days. Marketing calls and text messages must satisfy the Telephone Consumer Protection Act and applicable regulations, including consent, identification, do-not-call and revocation requirements where applicable. The fact that a list was purchased, publicly available or supplied by an agency does not establish permission for every proposed use. The client must provide evidence of the permissions or other lawful basis needed for the actual campaign. Both the sender and another party responsible for initiating or directing a communication may have obligations. General acceptance of these terms is not consent to automated marketing calls, promotional texts or disclosure of recipients’ information for unrelated purposes.
Artificial intelligence and synthetic content
AI-assisted advertising remains subject to the same requirements concerning truthfulness, substantiation, intellectual property, privacy and identifiable commercial intent as other advertising. Fabricated customers, invented expert endorsements, deceptive synthetic testimonials and misleading impersonations are prohibited. A synthetic person or altered recording must not be presented as evidence of a real person’s experience or endorsement when that impression is false. Where artificial generation or material alteration would affect a reasonable reader’s understanding of the advertisement, an appropriate disclosure must be included. Applicable statutory disclosure requirements must also be observed. Names, likenesses, voices and other identifying features require the permission or other lawful basis appropriate to the use, including under California Civil Code sections 3344 and 3344.1 where applicable. AI-generated product demonstrations must not misrepresent actual functionality or results. Use of an automated tool does not transfer the advertiser’s or supplier’s legal responsibility to the tool.
0.2. Legal framework and relevant case law
The following legislation and regulatory instruments are relevant according to the campaign, the contractual relationship, territorial scope and applicable statutory conditions:
- Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45, concerning unfair or deceptive acts or practices, together with applicable federal rules governing advertising and commercial conduct.
- California’s Unfair Competition Law, Business and Professions Code sections 17200–17210, and False Advertising Law, Business and Professions Code sections 17500 and following, concerning unlawful, unfair, fraudulent and misleading commercial practices.
- The California Consumers Legal Remedies Act, Civil Code sections 1750–1784, including restrictions on waiver of protected rights and the price-transparency requirements in section 1770(a)(29), where the transaction falls within its scope.
- Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), concerning qualifying claims involving false advertising, false designation and misleading representations of affiliation or endorsement.
- The Federal Trade Commission’s Rule on the Use of Consumer Reviews and Testimonials, 16 C.F.R. Part 465; the Consumer Review Fairness Act, 15 U.S.C. § 45b; and California Civil Code section 1670.8.
- The California Automatic Renewal Law, Business and Professions Code sections 17600–17606, and the Restore Online Shoppers’ Confidence Act, 15 U.S.C. §§ 8401–8405, where applicable to recurring consumer offers.
- The United States Copyright Act, the Lanham Act, California’s statutory and common-law protections for identity and publicity, and applicable rules concerning defamation, confidentiality and privacy.
- The California Consumer Privacy Act and its implementing regulations; the California Online Privacy Protection Act; applicable California information-security, breach-notification and communications-privacy provisions; and the Children’s Online Privacy Protection Act and implementing rule.
- The CAN-SPAM Act, the Telephone Consumer Protection Act and applicable implementing regulations governing commercial email, regulated calls and text messages.
- The Federal Election Campaign Act and relevant Federal Election Commission regulations; the California Political Reform Act; and applicable election-advertising, disclosure and financing requirements.
- The Fair Housing Act, applicable federal employment and credit laws, the California Fair Employment and Housing Act and the Unruh Civil Rights Act within their respective scope.
- The Federal Food, Drug, and Cosmetic Act, applicable alcohol and tobacco laws, California’s cannabis-advertising provisions, relevant gambling restrictions, federal securities laws and California’s financial-services and digital-asset requirements.
- California’s Voluntary Carbon Market Disclosures Act and applicable prohibitions on misleading environmental, sustainability and product-origin claims.
- California Civil Code provisions governing formation, interpretation, unconscionability, prohibited liability releases, liquidated damages, breach, interest and excuse of performance.
- The Electronic Signatures in Global and National Commerce Act and the California Uniform Electronic Transactions Act, concerning qualifying electronic agreements, signatures and records.
The Federal Trade Commission’s Endorsement Guides, 16 C.F.R. Part 255, Green Guides, 16 C.F.R. Part 260, and guidance on native advertising explain the agency’s interpretation of relevant legal standards. They must be distinguished from independently enforceable statutory provisions and trade regulation rules. Industry measurement standards are contractual or technical standards where adopted; they do not constitute governmental approval.
Relevant decisions include Kasky v. Nike, Inc., 27 Cal.4th 939 (2002), concerning the treatment of specified corporate promotional statements as commercial speech; POM Wonderful LLC v. Coca-Cola Co., 573 U.S. 102 (2014), concerning the availability of a Lanham Act challenge notwithstanding the federal food-labeling regime; Berman v. Freedom Financial Network, LLC, 30 F.4th 849 (9th Cir. 2022), concerning reasonably conspicuous notice and assent to online terms; Douglas v. United States District Court for the Central District of California, 495 F.3d 1062 (9th Cir. 2007), concerning attempted contractual changes through website posting without appropriate notice and acceptance; Ridgley v. Topa Thrift & Loan Association, 17 Cal.4th 970 (1998), concerning an unenforceable contractual penalty; and City of Santa Barbara v. Superior Court, 41 Cal.4th 747 (2007), concerning a prospective release of liability for gross negligence in the recreational-services context. Each decision must be applied according to its holding and the circumstances of the particular dispute.
1. Orders and formation of the contract
An advertising inquiry does not itself create a payment obligation. Before acceptance, the client must receive the campaign specifications, supplier identity, price and currency, applicable charges, payment schedule, campaign duration, cancellation arrangements and these terms in a form that can be retained. The order must identify whether an agency acts as principal or as an authorized representative of a named client. A contract arises through a valid offer and acceptance in the manner stated for the particular transaction. An automated acknowledgment is not acceptance unless expressly identified as such. Online contracting requires reasonably conspicuous notice of the applicable terms and an unambiguous manifestation of assent in the circumstances. Merely visiting a page or encountering an inconspicuous link does not establish agreement to every provision. Clients must have a reasonable opportunity to review the order and correct material input errors. Conflicting purchase-order conditions must be resolved through the applicable contract-formation rules; these terms do not create a fictional agreement merely because one party has remained silent.
2. Advertising placement and publication dates
The accepted order determines the publication channel, placement, format, dimensions, targeting, dates, duration and any guaranteed delivery volume. A rotating placement may appear alongside other advertisers according to the agreed arrangements. Exclusivity, a fixed position, specified surrounding content or guaranteed visibility must be expressly agreed. The supplier must not substitute another publication, materially different audience, format or campaign period without agreement where that change affects the promised service. Minor technical adjustments are permitted only insofar as they preserve the agreed substance and presentation. The client must identify time-critical events before acceptance, and any essential publication date must be recorded. A later placement is not necessarily an adequate remedy for an advertisement whose commercial purpose depended on a particular date. Any material brand-safety, geographic or audience-exclusion requirement must be included in the accepted campaign specification.
3. Refusal, suspension or termination of publication
Before contracting, the supplier may decline advertising on lawful grounds, including incompatibility with disclosed advertising standards, insufficient compliance information or unavailable inventory. After acceptance, suspension or removal requires a reasonable contractual or legal basis, such as unlawful content, substantiated rights infringement, a material security risk, a binding regulatory requirement or a material breach. Where practicable and appropriate, the supplier will explain the issue and allow a reasonable opportunity to correct it. Immediate action may be taken where necessary to prevent harm or comply with law. Measures must be proportionate to the affected material and circumstances. Suspension does not automatically entitle the supplier to retain the entire campaign price. Charges for services actually supplied, any legally recoverable compensation and refunds for undelivered services must be assessed separately. The supplier’s own breach remains subject to applicable remedies. A lawful advertising complaint or protected criticism does not, by itself, justify retaliation or forfeiture.
4. Delivery of advertising materials
The client must supply complete materials, destination links, required disclosures and supporting documentation by the agreed deadline and in the agreed technical format. Materials must be free from malicious code, unauthorized tracking, deceptive controls and undisclosed redirects. The supplier must communicate material technical requirements before the submission deadline. Landing pages must remain consistent with the approved advertisement and must not be changed to introduce unlawful claims, undisclosed charges or materially different products. Material alterations to wording, claims or visual meaning require the client’s approval, except where immediate restriction or removal is necessary under section 3. Additional design, conversion or correction work is chargeable only where its scope and price have been agreed. Approval of a proof does not excuse an error introduced afterward by the supplier. Clients should retain their own copies. Requests for return of physical originals should be made within ten days after the final placement; that administrative period does not extinguish ownership, statutory rights or an otherwise valid claim.
5. Defective performance and complaints
The supplier will deliver the agreed service with reasonable care and in accordance with the accepted specifications. Clients should report missing, incorrect or defective placements promptly so that effective correction remains possible, but a claim is not automatically barred because it is made after the campaign ends or the final report is issued. The supplier will investigate, explain its findings and provide the remedy required by the contract and applicable law. Depending on the circumstances, an appropriate remedy may include correction, replacement delivery, an agreed extension, a price adjustment, a refund or another legally available remedy. Replacement delivery must serve the campaign’s remaining purpose and must not be imposed where it would not reasonably remedy the failure. If the supplier cannot provide a material contracted deliverable, prepaid amounts attributable to the undelivered service must be refunded, subject to any additional rights. Refunds must be processed promptly and within applicable legal deadlines. These terms do not impose an artificial complaint deadline that eliminates a claim before the applicable limitation period expires.
6. Rights in materials and third-party claims
The client must hold the rights, permissions or other lawful basis necessary for the supplied text, images, recordings, trademarks, personal information and other material. The client grants the supplier a nonexclusive license limited to producing, technically adapting, delivering and reporting on the agreed campaign. Technical providers may exercise those rights only to the extent required for their appointed functions. Submission or payment does not automatically transfer copyright ownership. Where the supplier creates campaign material, the agreed license or ownership allocation must identify the client’s permitted uses, any limitations and the treatment of third-party assets. Any claimed work-made-for-hire status or copyright assignment must satisfy the applicable statutory conditions. Unrelated reuse, resale, use for another advertiser or unrelated AI training requires an appropriate additional basis. Applicable attribution, publicity, privacy and other protected rights must be respected. Responsibility for third-party claims depends on the relevant conduct, breach, causation and applicable law. These terms do not impose an unlimited indemnity for every allegation or for the supplier’s own wrongdoing. Neither party may bind the other to an admission, settlement or defense expense without authority or another valid legal basis.
7. Liability and expected campaign results
The supplier is responsible for its agreed obligations and its own legally attributable acts and omissions. Unless expressly promised, a campaign does not guarantee a particular level of sales, inquiries, profit, search ranking or return on investment. That qualification does not reduce an agreed commitment concerning placement, duration, audience criteria, valid impressions or another defined deliverable. These terms do not exclude liability for fraud, intentional misrepresentation, willful injury, gross negligence or other liability that cannot lawfully be excluded or restricted. California Civil Code sections 1668 and 1670.5 and applicable consumer protections remain controlling. No automatic limitation to the amount of the campaign fee is imposed by these terms. Any separately negotiated limitation must be legally effective and properly incorporated. Questions of causation, recoverable loss, mitigation and defenses remain governed by law. Use of an external technical provider does not automatically release the supplier from contractual responsibility. Any statutory intermediary protection must be assessed according to the actual activity and claim; describing material as third-party advertising does not eliminate responsibility for the supplier’s own unlawful conduct or representations.
8. Price, advance payment and campaign cancellation
The agreed price and payment schedule must be disclosed before the contract is formed. Unless otherwise agreed, payment is due in advance by the date stated in the accepted offer and corresponding invoice. Design, production, targeting, measurement or other additional services may not be charged without a contractual basis. A request to cancel or reduce a campaign will be assessed under the agreed arrangements and applicable law. Any cancellation charge must be validly agreed or otherwise legally recoverable. Where a provision constitutes liquidated damages, California Civil Code section 1671 and the rules applicable to the particular business or consumer transaction must be satisfied; an unenforceable penalty is not recoverable merely because it is described as a cancellation fee. The supplier must account for costs saved and legally required mitigation. Cancellation does not automatically make all remaining charges payable or eliminate a refund for undelivered services. Advertising credit will not be imposed in place of a monetary refund that is due. No campaign renews automatically or creates recurring charges unless those arrangements have been clearly disclosed and validly accepted. Covered consumer arrangements must additionally comply with the California Automatic Renewal Law and the Restore Online Shoppers’ Confidence Act.
8.1. Authorized payment recipient
Advertising payments may be collected on the supplier’s behalf by:
LEGIER Beteiligungs mbH
Kurfürstendamm 14
10719 Berlin
Federal Republic of Germany
Commercial register: HRB 57837
Registration court: Amtsgericht Charlottenburg, Berlin
VAT identification number: DE413445833
Email: [email protected]
Payment made to an account identified in a valid invoice as an authorized collection account discharges the corresponding payment obligation to SCANDIC TRUST GROUP LLC to the extent received. The invoice must accurately identify the supplier and the capacity in which payment is collected. The German collection address does not, by itself, determine the place of supply, applicable tax treatment or governing law. Responsibility for the advertising service and a refund owed by the supplier remains with the supplier. Changes to payment instructions must be communicated through an authenticated channel. Clients may verify changed instructions through the established contact details before transferring funds. No different contracting party is substituted merely because payment is received by LEGIER Beteiligungs mbH.
9. Late payment
If an undisputed amount is overdue, the supplier may issue a payment reminder and, after appropriate notice, suspend the affected service to the extent reasonably justified. Interest, collection expenses and attorney’s fees require a valid contractual or statutory basis. Where California Civil Code section 3289(b) applies to a contract that does not stipulate a lawful interest rate, the statutory rate is 10% per year after breach, subject to the applicable rules governing entitlement, accrual and recovery. This provision does not authorize duplicate interest, an unlawful penalty, unsupported collection charges or automatic acceleration of unrelated debts. A reasonable dispute concerning part of an invoice does not automatically excuse payment of an undisputed amount, but the dispute must be assessed fairly. A suspension must not be used to retain payment for services the supplier will not provide without an appropriate contractual or legal basis.
10. Exceptional events affecting performance
A party may rely on this section only where an event beyond its reasonable control prevents the affected performance despite reasonable preventive and mitigating measures. The affected party must notify the other promptly, explain the effect on the campaign and take reasonable steps to limit disruption. Relief is confined to the obligations and period actually affected. Increased expense, reduced profitability, ordinary staffing difficulties or an unexplained supplier failure do not automatically qualify. Cyber incidents and outages must be assessed against the circumstances and the precautions reasonably required. Alternative performance that materially changes the contract requires agreement. If an interruption defeats an essential campaign purpose or prevents delivery within the agreed period, the client may terminate the affected undelivered portion and receive the refund due, subject to lawful accounting for services already supplied. California Civil Code section 1511 and applicable doctrines of impossibility, impracticability or frustration may apply according to their requirements. This clause does not excuse an earlier breach, eliminate reasonable mitigation duties or grant a blanket release from liability.
11. Applicable version and changes to these terms
The version validly incorporated when the contract is formed governs that contract. Publication of revised terms does not retrospectively amend an accepted campaign. Changes to an existing agreement require valid agreement unless a sufficiently specific and enforceable contractual provision or applicable law permits the particular change. Material amendments must be explained in a form the client can retain, including their effect and proposed effective date. Silence or continued access to a public webpage does not, by itself, establish agreement to a new price, additional charge or reduced service. Accrued claims and completed transactions are not retroactively altered by a new version. Mandatory legal changes apply according to their own provisions.
12. Consumer cancellation rights
California and federal law do not provide a general 14-day cooling-off period for every online advertising order. Most purchases of advertising for a business or professional activity are commercial transactions, although status depends on the actual circumstances and the relevant statute. A particular statutory cancellation or rescission right may apply to a qualifying transaction, including certain transactions conducted away from the seller’s usual place of business. Where applicable, the Federal Trade Commission’s Cooling-Off Rule, 16 C.F.R. Part 429, or California’s Home Solicitation Sales Act must be observed according to their scope, exemptions and notice requirements. These provisions must not be represented as a universal right to cancel every internet purchase. Contractual cancellation rights, remedies for misrepresentation or nonperformance and mandatory refund rights remain available independently of any cooling-off period.
Starting work during a cancellation period
Where a particular statutory cancellation right applies, the supplier must provide the required disclosures and follow the rules governing performance, cancellation and any permitted payment for work already undertaken. Permission to start work does not, by itself, waive a nonwaivable statutory right. The fact that an advertisement is customized does not automatically decide whether the advertising-service contract is cancellable. Outside an applicable statutory cancellation regime, authorization to begin production or publication has the effect stated in the accepted order, subject to the restrictions on unlawful penalties and other mandatory protections. Work must not be started without authority merely to create a cancellation charge.
Separate digital materials and refunds
Where an order includes separately supplied creative assets, software or other digital materials, the applicable rights depend on the actual agreement and the relevant law. An advertising placement must not be reclassified merely to avoid a valid cancellation or refund obligation. Where a refund is due, the supplier will provide an understandable account of the amount, any lawful deduction and the method of reimbursement. The original payment method will ordinarily be used unless another lawful method is agreed. Collection of the original payment through an authorized recipient does not transfer or postpone the supplier’s refund obligation. No refund fee will be deducted from an amount that the law requires to be returned in full.
How to cancel
A client may request cancellation by sending a clear statement to [email protected] or to the supplier’s correspondence address in section 13. Any additional method required by law or agreed for the campaign remains available. The request should identify the order and the extent of the requested cancellation. Where a statutory deadline applies, its rules governing timely notice must be followed. Cancellation does not require discretionary approval where the client has an applicable legal or contractual right. For a recurring consumer service accepted online, the legally required online cancellation mechanism must remain available without obstructive steps. The supplier will confirm the effective date and explain any remaining lawful charges or refund.
To: SCANDIC TRUST GROUP LLC
IQ Business Centre
Bolsunovska Street 13–15
01014 Kyiv / Ukraine
Email: [email protected]
A client may reply to the relevant order confirmation using the following optional wording: "I cancel the advertising order identified in this correspondence to the extent permitted by my contractual and statutory rights. Please confirm the effective cancellation date, stop any canceled future placements and provide an account of any refund or amount lawfully remaining due." Another clear cancellation statement is equally acceptable.
13. Addresses and contact details
The advertising supplier and contracting party may be contacted at its operational and correspondence address:
SCANDIC TRUST GROUP LLC
IQ Business Centre
Bolsunovska Street 13–15
01014 Kyiv / Ukraine
Email: [email protected]
Website: www.rcaTelegramNewsCalifornia.com
Legal form: limited liability company incorporated under Ukrainian law
Registration number: 1010351020000018952
Registered office and company address
SCANDIC TRUST GROUP LLC
Oksamytova Street 1-b, Office 30
Sofiivska Borshchahivka
Kyiv Region - 08147 / Ukraine
Technical operation and administration
SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2
Dubai - 342001 / United Arab Emirates
Telephone: +971 54 221 5217
SCANDIC ASSETS FZCO performs technical functions within the scope of its appointment. The Ukrainian registration number identifies SCANDIC TRUST GROUP LLC and is not a California or other United States company registration number. Contractual notices, complaints and refund requests may be addressed to the supplier using the contact details above. Special legal requirements for service of proceedings remain unaffected.
14. Backups and retention of information
Campaign materials, correspondence, delivery records and accounting information will be retained only for the purposes and periods reasonably required for performance, administration, compliance and the establishment, exercise or defense of legal claims. Routine administrative personal information will ordinarily be deleted or anonymized when no longer needed and no later than twelve months after campaign completion and final settlement, unless a longer period is justified by a specific legal obligation, unresolved dispute or another documented lawful necessity. That period is not a universal retention period for accounting, tax, election, consent or evidentiary records. Backups must be subject to appropriate security, restricted use and a defined deletion or overwrite cycle. Restoring a backup must not authorize unrelated republication or disregard an applicable deletion restriction. Service-provider and contractor arrangements must contain the restrictions required by applicable privacy law. International processing must satisfy the laws applicable to the information and activity concerned; use of an overseas company is not a waiver of California privacy rights. Further information is provided in the Privacy Policy.
15. Technical systems and security commitments
The supplier will maintain administrative, technical and physical safeguards appropriate to the services, the information handled and the reasonably foreseeable risks. Measures may include access controls, secure transmission, monitoring, vulnerability management, backups and incident response. No system is represented as immune from interruption or attack. Where a particular security product, certification or assurance level is expressly agreed, the contractual documentation must identify the relevant product, version, configuration, evaluation scope and supporting evidence. A Common Criteria certificate, including one referring to Evaluation Assurance Level 7, concerns the defined evaluated product and configuration; it must not be represented as certification of the entire publication, hosting environment or advertising service without supporting evidence. An agreed security requirement must not be silently replaced by a lower specification. Security incidents must be investigated and addressed promptly, with notifications made where required by applicable law or the contract.
16. Measurement, reach and assessment of results
Campaign measurement must distinguish the following concepts:
- Page impressions: recorded displays of webpages under the stated methodology; a page impression does not establish that a particular advertisement was displayed.
- Advertising impressions: recorded deliveries or displays of an advertisement under the agreed counting rules.
- Viewable impressions: impressions meeting expressly identified visibility criteria and measurement requirements.
- Unique visitors or reach: estimates produced under the stated methodology; a browser, device or identifier does not necessarily correspond to one individual.
- Clicks and interactions: measured events whose definition, filtering and attribution must be explained where they affect reporting or payment.
- Conversions: specified outcomes attributed under the agreed method and attribution period, subject to the limitations of the available evidence.
The order must identify the metrics that determine delivery and invoicing, the measurement system and material limitations. CPM means the price per 1,000 valid advertising impressions under the agreed methodology; webpage impressions must not be substituted without express agreement. Identified invalid or fraudulent traffic must not be billed as valid advertising delivery. Material discrepancies between systems must be investigated rather than dismissed solely because the supplier’s system produced a different result. Privacy choices, advertising blockers and technical restrictions may affect measurement, but they do not authorize circumvention of a reader’s rights or the billing of undelivered impressions. Seasonal changes and fluctuating news interest do not remove a guaranteed delivery commitment. Any reference to an industry standard, independent audit or accreditation must accurately identify what has been assessed.
17. Orders and prices
Advertising orders concern www.rcaTelegramNewsCalifornia.com unless additional publications or channels are expressly identified in the accepted order. The minimum order value for business and professional clients is EUR 5,500, excluding taxes lawfully applicable to the particular transaction. Business prices stated in sections 17 to 20 are exclusive of such taxes. A tax must not be charged merely because the authorized payment recipient has a German address. California sales or use tax, foreign VAT or another transaction tax applies only where the relevant legal requirements are satisfied. The offer and invoice must identify the actual tax treatment. A consumer must receive a compliant offer disclosing the full price and mandatory charges in accordance with applicable law, together with any separately stated tax permitted by that law. Prices are denominated in euros unless another currency is expressly agreed. Any agreed currency-conversion method or payment charge must be disclosed before acceptance. Contextual targeting, search optimization, remarketing and behavioral targeting must be expressly described and performed lawfully. A restriction preventing an unlawful targeting method does not automatically create an entitlement to payment for an undelivered service.
18. Premium placements and special advertising formats
Subject to availability and the accepted campaign specifications, options may include:
- Rotating placements within relevant subject areas, including business, automotive news, information technology and telecommunications.
- Rotation across additional publications or websites expressly named in the order.
- An additional reminder button measuring 160 × 50 pixels at a CPM of EUR 5, excluding applicable taxes for business and professional orders.
- Combinations of formats and placements under an individual proposal.
- Display advertising, Medium Rectangle placements and video, subject to the agreed dimensions, functionality and technical requirements.
The offer must identify available inventory, campaign duration, targeting criteria, the measurement basis and material compatibility requirements. Exclusivity or continuous visibility on every device is promised only where expressly agreed. Any such agreement forms part of the supplier’s binding obligations. A format name or general reference to an industry specification does not replace a clear description of the actual deliverable.
19. Annual volume discounts
The following discounts apply to one client’s total eligible advertising order value within the same calendar year, calculated before the annual discount and excluding taxes:
- From EUR 15,000: 2.5%.
- From EUR 50,000: 5%.
- From EUR 100,000: 10%.
- From EUR 150,000: 15%.
- From EUR 250,000: 20%.
- From EUR 500,000: 25%.
The rate for the highest attained band applies to the entire eligible annual volume; the percentages are not cumulative. Any service exclusions or additional eligibility conditions must be disclosed and validly agreed before the affected order is accepted. Final reconciliation must account for discounts already credited, cancellations and refunds, with sufficient information to verify the calculation. Where an advance discount depends on a binding annual commitment, a shortfall adjustment requires a previously agreed lawful mechanism and must be confined to the difference between the discount granted and the discount actually earned. No adverse adjustment may be imposed to the extent that the supplier caused the shortfall. Reconciliation must not unlawfully penalize the exercise of statutory rights. Discounts for regulated campaigns, including political advertising, remain subject to applicable restrictions on contributions, subsidies and other benefits.
20. Campaign reporting, invoicing and agency commission
Usage-based invoicing must be supported by a campaign report using the agreed metrics. The client may request an explanation of discrepancies and submit relevant evidence from another measurement system. The supplier’s report is evidence of performance, not conclusive proof that cannot be challenged. Prompt reporting assists correction during the campaign, but a claim does not lapse merely because it is raised after final reporting. For an order introduced through an advertising agency, the agency commission is 10% of the invoiced advertising service price after agreed discounts and before taxes, unless another basis is expressly agreed. The proposal must identify the entitled agency and explain how the commission is settled. The same commission or discount must not be counted twice on the same basis. An agency must disclose whether it acts in its own name or for a named principal and must comply with applicable duties concerning authority, conflicts of interest and compensation disclosure. Agency involvement does not establish authority to bind a client beyond the authority actually granted.
21. Advertising formats
Depending on availability, compatibility and the agreed service, the following formats may be offered:
- Rotating horizontal display advertising, including Full Banner.
- Superbanner.
- Layered formats and interactive HTML5 advertising.
- Pop-up and pop-under formats where lawful and supported by the relevant browser.
- Content Ads placed near editorial material with clear advertising identification.
- Vertical display formats, including Skyscraper.
- Advertising information strips, including Newsticker formats.
- Advertising bars, including Ad Bars.
- Expandable corner formats, including Page Peel.
- Interstitial and Superstitial formats.
- Video and other expressly agreed multimedia formats.
Presentation must respect privacy choices, applicable protections for children and reasonable user control. Deceptive buttons, false system warnings, concealed charges, unauthorized downloads and circumvention of browser security are prohibited. Controls for closing or dismissing an advertisement must not be deliberately disguised or misleading. Essential disclosures must remain understandable and must not depend solely on inaccessible animation, sound or an avoidable interaction. Applicable accessibility and nondiscrimination requirements must be considered in design and delivery. The description of a format does not represent obsolete browser technology as currently supported.
22. Clients, businesses and consumers
A client is the person or organization entering into the advertising contract. A business client purchases advertising for purposes connected with its trade, business or profession. Consumer status depends on the actual transaction and the definition in the relevant statute. Under the California Consumers Legal Remedies Act, a consumer is an individual who seeks or acquires goods or services for personal, family or household purposes through a covered transaction. Other laws may use different definitions or protect businesses as well as individuals. An individual purchasing an advertisement for a personal purpose must not be deprived of an applicable protection merely through an invoice heading, business-style email address or standard-form declaration. Conversely, a commercial advertising purchase is not automatically a consumer transaction because the client is a natural person. These terms do not require waiver of a legally protected status.
23. Attachments and contractual documentation
Campaign specifications, schedules, artwork approvals, price lists, technical requirements and data-processing arrangements form part of the contract only where properly identified and incorporated. Material documents must be accessible before acceptance and supplied or confirmed in a retainable form where required. Individually agreed campaign provisions take precedence over inconsistent standard provisions, subject to mandatory law. An attachment must not conceal an additional charge, materially reduce a disclosed deliverable or introduce an unexpected restriction without appropriate notice and agreement. A document supplied after formation does not automatically amend the contract. Operational correspondence may clarify performance without changing the agreed commercial substance. Electronic signatures and records must satisfy the requirements applicable to their intended use, including any relevant consumer-consent requirements.
24. Contracting parties and allocation of responsibilities
The advertising contract is between the identified client and SCANDIC TRUST GROUP LLC. "RCA TELEGRAM NEWS CALIFORNIA" is the publication’s title and does not constitute a separate legal entity. SCANDIC ASSETS FZCO performs appointed technical functions, and LEGIER Beteiligungs mbH receives authorized payments and handles advertising inquiries within its authority. Each company remains responsible for obligations arising from its own activities and any undertaking it actually gives. Delegating performance does not itself release the supplier. Substitution of another contracting party requires the legal steps and any consent necessary for an effective transfer of obligations; it must not be achieved merely by changing an invoice heading or website notice. An assignment of rights must comply with applicable law and must not unlawfully reduce the client’s defenses, remedies or mandatory protections.
25. Invalid, unfair or unincorporated provisions
The effect of an invalid, unenforceable, unconscionable or unincorporated provision is determined by applicable law. California Civil Code section 1670.5 permits the treatment of an unconscionable contract or clause according to the statutory requirements. Whether the remainder of an agreement continues depends on the applicable severability rules and the circumstances of the agreement. An ineffective provision is not automatically replaced by whichever term would produce the greatest economic advantage for the supplier. Ambiguities are interpreted under the governing rules of contract interpretation, including California Civil Code section 1654 where applicable. Mandatory consumer protections cannot be waived through this section. A failure to enforce a provision on one occasion does not automatically waive a later lawful right, but an effective waiver or binding course of conduct remains subject to law.
26. Governing law, jurisdiction and dispute resolution
These terms and agreements into which they have been validly incorporated are governed by California law and applicable federal law, subject to controlling conflict-of-laws rules and mandatory protections. This choice does not remove rights or procedural protections that another applicable law makes nonwaivable. Jurisdiction and venue are determined by the applicable legal rules. These terms do not impose an exclusive foreign forum, mandatory arbitration, a class-action waiver, a jury-trial waiver or a waiver of public injunctive relief. Clients may submit contractual complaints to [email protected]. The supplier will consider the complaint and explain its outcome. Mediation or another appropriate procedure may be agreed voluntarily, without restricting access to competent courts or regulators. Depending on the subject, complaints may fall within the responsibilities of the Federal Trade Commission, the California Attorney General, the California Privacy Protection Agency, the Federal Election Commission, the California Fair Political Practices Commission or another competent authority. Those bodies have distinct functions and do not automatically determine contractual refund claims. Informal complaint handling does not suspend a limitation period unless the law or a valid agreement provides otherwise.
Contact:
"RCA TELEGRAM NEWS CALIFORNIA"
Email: [email protected]
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Last updated: 1 November 2026.