Terms and Conditions

A1. About these Terms

These Terms and Conditions (“Terms”) govern the use of the website panion.travel, the Panioncheckout used on operators’ own websites, and related services (the “Platform”). The Platform is operated by Panion Norge AS, org.nr 937 759 614, registered business address Tønsnesvegen 14, 9020 Tromsdalen, Norway (“Panion”, “we”, “us”). Contact: hello@panion.travel.

“Provider” means the company that sells an Activity through the Platform and is named as seller at checkout. “Activity” means a tour, experience, ticket or accommodation stay offered through the Platform. “Panions” (with capital P) are the businesses and self-employed people who publish curated lists and refer Customers to the Platform in exchange for commission.

The Terms apply to three groups of users:

• Part B: Customers who book Activities through the Platform.
• Part C: Providers who sell Activities through the Platform.
• Part D: Panions who refer Customers and earn commission.

Part A and Part E apply to all users. The other parts apply only to the relevant user group. Part B is also available in Norwegian; both language versions are equally valid.

A2. How the Panion model works

Panion is a booking agent (formidler) and technology provider. Panion does not sell Activities in its own name and is not the organiser or performer of any Activity.

When a Customer books, the contract for the Activity is made directly between the Customer and the Provider named as seller at checkout and in the booking confirmation. Panionarranges the booking and the payment on the Provider’s behalf and is responsible only for its own booking service.

Panion’s fee is a commission that the Provider pays. Customers pay no booking fee to Panion. Panions (for example hotels, hosts and guides) may receive a commission from Panion on bookings made through their link or QR code; this never changes the price the Customer pays.

A3. Acceptance

You accept these Terms by:

(a) booking an Activity (Customers); (b) creating a Provider account, listing an Activity, or accepting a booking (Providers); (c) creating a Panion account or publishing a Panion link or QR code (Panions).

If you do not accept these Terms, do not use the Platform.

A4. Changes to the Terms

We may update these Terms from time to time. Material changes will be notified to registered users by email and published on the Platform at least 30 days before they take effect for them. For Customers, a booking is governed by the Terms in force on the day the booking was made.

A5. This version and when it applies

This is version 3.4, published 22 October 2026.

• Everyone: version 3.0 applies to Customers, Providers and Panions from 15 October 2026 and replaces version 2.0 from that date. Version 3.1 replaces version 3.0 from 16 October 2026, and changes the rules on refunds and cancellations for Providers in C4.3 and C6.2. Version 3.2 replaces version 3.1 from 17 October 2026, and version 3.3 replaces version 3.2 from 17 October 2026. Version 3.4 replaces version 3.3 from 22 October 2026. It changes the refund of the reserve fee when the Provider cancels or the Activity cannot take place (B4, B7, B8, C4.2, C6.4 and E6.2), the commission on cancellations by the Provider (C4.3, C4.5, C4.6 and C6.2), personal data (C10 and the data processing agreement in Annex 1), the notice period for ending the Provider relationship (C13), and this A5.
• Earlier bookings: version 3.0 also describes how every booking made through the Platform has been processed since launch. For all bookings, including those made before 15 October 2026, the Provider is the seller and Panion acted as its booking agent, and the reserve fee was kept by Panion as described in C1, C4.2 and C4.6. Where version 2.0 gave a Customer a right that is more favourable than version 3.0 for a booking made under it, the Customer keeps that right.
• Reserve fee (version 3.4): when the Provider cancels, or the Activity cannot take place because of force majeure, on or after 22 October 2026, the Customer is refunded in full, including the reserve fee (B4, B7 and B8). This applies to every booking made through the Platform, whenever it was made, and applies instead of A4 and of any earlier version. When the Customer cancels, the reserve fee is not refunded. This does not limit any right you have under mandatory consumer law.
• Providers (version 3.4): version 3.4 applies to Providers from 22 October 2026. A Provider that accepted an earlier version is asked to accept version 3.4 on behalf of its business when it next signs in, and also accepts it by accepting a booking after that date (C1.3). The rules on cancellations by the Provider in C4.3 and C6.2 apply to cancellations made on or after 22 October 2026; the cancellation fee in C6.2 of versions 3.1 to 3.3 applies only to cancellations made from 16 October 2026 until the day before 22 October 2026.
• Refunds (version 3.1): the credit of commission on refunded amounts (C4.3) applies to every booking, including refunds made before 16 October 2026, on the invoices Panion issues or re-issues from that date.
• VAT on commission: commission rates include VAT (C4.4). For bookings made on or after 15 October 2026, the 2.42% rate becomes 3% including VAT on amounts collected from the date Panion is entered in the VAT register. Commission on earlier bookings, and commission collected before that date, stays at the rate applied and is treated as including any VAT due.

Every version stays available at its own address so that past acceptances can always be checked against the text accepted.

B1. Who you are contracting with

B1.1 The seller.Your contract for the Activity is with the Provider named as seller at checkout and in your booking confirmation, with its legal name and organisation number (“Sold by” or “Sold and operated by”). The Provider is responsible for delivering the Activity and for the Activity’s price, VAT and receipt. Where the seller resells an Activity run by another company, that company is shown as the operator, and the seller remains your contracting party.

B1.2 Panion’s role. Panion Norge AS, org.nr 937 759 614, Tønsnesvegen 14, 9020 Tromsdalen, Norway, hello@panion.travel, is the booking agent and technology provider. Panionruns the checkout and booking pages, passes your booking to the Provider, provides the checkout through which you pay the Provider, and sends your confirmation and receipt on the Provider’s behalf.

B2. Information before you book

Before you book you are shown the seller’s identity, the total price including VAT, the date, time and main features of the Activity, the cancellation rules, any pay-later terms, and these Terms. You can correct your details before confirming. The contract is concluded in English or Norwegian.

B3. Booking, prices and payment

B3.1 A binding contract between you and the Provider is formed when you complete the booking and receive a booking confirmation by email.

B3.2 Prices are set by the Provider, are stated in the currency shown at checkout and include VAT. Panion adds no booking, service or card fee. A display in another currency is for information only; you are charged in the currency shown at checkout.

B3.3 Payment is processed by SagaPay to the merchant account of the seller named at checkout. Paniondoes not store full card details. Your card statement may show “PANION” as part of the description.

B3.4 Where a saving for booking direct is shown, it compares the price with the price of the same Activity on the same date on GetYourGuide or another online travel agency (OTA).

B4. Reserve now, pay later

Where the checkout offers to pay later, these rules apply:

• Reserve fee. You pay a reserve fee when you book (29 NOK or 3 EUR, or the amount shown at checkout). The reserve fee is part of the price of the Activity and is deducted from your total. It is not an extra charge.
• Balance. The rest of the price is charged automatically to the card you used, 7 days before the Activity starts. If you book later than that, the balance is charged 3 days before the Activity starts. The charge date is stated at checkout and in your confirmation, and we email you before the charge.
• If you cancel. The reserve fee is non-refundable if you cancel, including when you cancel inside a free-cancellation period. Everything else you have paid is refunded according to the cancellation rules of the Activity. A balance that has not been charged yet is not charged.
• If the Provider cancels or the Activity cannot take place because of force majeure (B8), everything you have paid is refunded in full, including the reserve fee (B7 and B8). A balance that has not been charged yet is not charged.
• Who keeps the fee. The Provider pays Panion a commission for each booking. On pay-later bookings, Panion keeps the reserve fee as part of that commission. When the reserve fee is refunded to you, the Provider pays the refund.
• If the balance cannot be charged. We email you a link to pay or update your card. If the balance is still unpaid by the deadline in that email, the booking is cancelled, your place is released, and the reserve fee is not refunded.

B5. No right of withdrawal

Under the Norwegian Right of Withdrawal Act (angrerettloven) § 22 (m), the 14-day right of withdrawal does not apply to leisure services or accommodation where the contract sets a specific date or period of performance. Activities booked through the Platform are for a specific date, so there is no statutory right of withdrawal. You can still cancel under the cancellation rules of the Activity (B6).

B6. Cancellation by you and refunds

B6.1 The Provider sets the cancellation rules for each Activity. They are shown on the Activity page, at checkout and in your confirmation, and form part of your contract. You can cancel from your booking page or by contacting the Provider or Panion.

B6.2 Refunds go back to the card used for payment. Where a card refund is no longer possible (for example a long time after payment), the Provider refunds you by bank transfer.

B6.3 If you do not show up, or arrive too late to take part, the booking counts as used and is not refunded, unless the cancellation rules say otherwise.

B7. Cancellation or changes by the Provider

If the Provider cancels the Activity, or changes it significantly, you are entitled to a full refund of everything you have paid, including any reserve fee. You may instead accept a new date if one is offered. We will tell you as soon as possible. Rights you have under mandatory consumer law, including compensation from the Provider, are not affected.

B8. Weather and force majeure

If the Activity cannot take place because of circumstances outside the Provider’s control (for example extreme weather, natural events, closed roads or government measures), you choose between a new date, if one is available, and a full refund of everything you have paid, including any reserve fee. Neither the Provider nor Panion is liable for further costs caused by such circumstances. This does not limit any right you have under mandatory consumer law.

B9. Taking part

B9.1 The Activity is performed by the Provider on the date and at the place stated in your booking. The Provider may contact you directly with practical information.

B9.2 You must follow safety instructions and meet the participation requirements (for example age, health or clothing) stated before you booked. If you do not meet them, the Provider may refuse participation for safety reasons. In that case the booking is treated as a no-show (B6.3), unless mandatory law gives you a refund.

B10. Accommodation and travel packages

For accommodation, your contract is with the hotel or accommodation provider named as seller. Where a stay is sold together with transport (for example a transfer) or other travel services so that it forms a package travel under the Package Travel Act (pakkereiseloven), the accommodation provider is the organiser of the package, is responsible for its performance and holds the required travel guarantee (reisegaranti). Panion acts only as booking agent.

B11. Complaints

B11.1 If something is wrong with the Activity, tell the Provider as soon as possible, preferably on the spot so it can be put right. You can also write to hello@panion.travel; we will pass the complaint to the Provider and help you get an answer.

B11.2 Complaints about Panion’s booking service (for example the checkout, payment handling or your confirmation) go to hello@panion.travel and are handled by Panion.

B11.3 If a complaint is not resolved, consumers can contact the Norwegian Consumer Council (Forbrukerrådet) for mediation and may bring the case before the Consumer Disputes Commission (Forbrukerklageutvalget). Consumers resident in another EU or EEA country can contact their national European Consumer Centre.

B12. Liability

B12.1 The Provider is responsible to you for the Activity, including its performance, safety and any defects, under the contract and mandatory consumer law.

B12.2 Panion is responsible only for its own booking service: that your booking is passed on and confirmed correctly, that the information Panion itself provides is correct, and that payments and refunds are handled as described in these Terms.

B12.3 Nothing in these Terms limits liability for death or personal injury caused by negligence, or any other liability that cannot be limited under mandatory Norwegian law.

B13. Panions' lists and recommendations

Lists published by Panions reflect the Panion’s own recommendation. A Panion may earn a commission from Panion on bookings made through its list; this does not change the price you pay.

B14. Personal data

How Panion and the Provider process your personal data is explained in the Privacy Policy.

B15. Governing law and disputes

Norwegian law applies. This does not deprive consumers resident in another country of the protection of mandatory rules of the law of that country. Consumers can bring a case before the courts where they live; any agreed venue does not bind consumers.

C1. Role and acceptance

C1.1 The Provider sells its Activities to Customers in its own name through the Platform. The contract for the Activity is between the Customer and the Provider. The Provider is responsible to the Customer for the Activity, its price, VAT, cancellation rules and the Customer’s rights under consumer law.

C1.2 The Provider appoints Panionas its booking agent and technology provider to market the Activities, take bookings, collect payment to the Provider’s own merchant account through SagaPay, and issue booking confirmations and receipts in the Provider’s name and on its behalf. Panionis not the seller, organiser or performer of any Activity, and is not the Provider’s employee or partner.

C1.3 The Provider accepts these Terms by creating a Provider account, listing an Activity, or accepting a booking.

C2. Listings, identity and content

C2.1 The Provider is responsible for the accuracy of all information about the Activity, including description, duration, meeting point, what is included, participant requirements, cancellation rules and available capacity. The calendar and capacity must be kept up to date.

C2.2 The Provider must keep its legal name, organisation number, VAT registration and address up to date in its account. Panion shows them to Customers as the seller at checkout, on the booking page and on receipts.

C2.3 Where a saving for booking direct is shown, the Provider must keep the reference price it gives Panion equal to the price at which the same Activity is offered through GetYourGuide or the online travel agency named, and tell Panion without delay when that price changes.

C2.4 The Provider grants Panion a non-exclusive, royalty-free, worldwide licence to use the text, photos, videos and trademarks the Provider uploads to promote and sell the Activity through the Platform, Panion’s marketing channels and Panions, and warrants that it holds the rights to that content.

C3. Quality, safety and compliance

By listing an Activity, the Provider confirms and warrants that:

(a) it holds all licences, permits, certifications and qualifications required by law to operate the Activity; (b) it complies with applicable law, including health, safety, environmental, animal welfare, consumer and tax rules; (c) its staff have the competence and language skills needed to deliver the Activity safely to international guests; (d) it maintains written safety routines and risk assessments; (e) it will notify Panion without undue delay of any incident, accident or near-miss involving Customers; (f) where it sells accommodation together with transport or other travel services, it is the organiser under the Package Travel Act and holds the required travel guarantee.

C4. Commission, VAT, invoicing and settlement

C4.1 Commission. The Provider pays Paniona commission on each booking, calculated as a percentage of the amount the Customer actually pays for the booking (including VAT and after any discount). The rates are those applied to the Provider’s bookings before these Terms:

• on bookings made through the Provider’s own website (the embedded Panion checkout), hosted checkout links, payment links and desk bookings: 3% including VAT from the date Panion is entered in the VAT register (C4.4), and 2.42% until then; and
• 25% including VAT on bookings made on panion.traveland through Panions’ links, unless a different rate is agreed for an Activity.

The rate applying to each booking is shown in the Provider’s reporting. Panionmay change rates with 30 days’ notice; a new rate applies only to bookings made after it takes effect.

C4.2 Reserve fee. On pay-later bookings the Customer pays a reserve fee at booking (29 NOK or 3 EUR, or the amount shown at checkout). It is part of the Activity price and is deducted from the balance. Panion keeps the whole reserve fee as part of its commission, and the commission rate applies to the balance. Panion never refunds the reserve fee and never credits it to the Provider. If the Customer cancels, the reserve fee is not refunded to the Customer. If the Provider cancels, or the Activity cannot take place because of force majeure, the Customer is refunded in full, including the reserve fee (B4, B7 and B8). The Provider pays that refund, including an amount equal to the reserve fee, from its own merchant account, and the reserve fee remains Panion’s commission.

C4.3 Refunds and cancellations. When an amount is refunded to the Customer, the commission on it is treated as follows:

• when the Customer cancels inside the free-cancellation period of the Activity and is refunded, the commission already collected on the refunded amount is credited to the Provider on the monthly invoice for the month of the refund. A partial refund is credited in proportion;
• when the Provider cancels because of weather, force majeure or genuine safety reasons (C6.2), the commission on the refunded amount is credited to the Provider in the same way;
• when the Provider cancels for any other reason (C6.2), nothing is credited: Panion keeps its full commission on the booking, and the Provider bears it in addition to refunding the Customer in full;
• when the Customer cancels outside the free-cancellation period and is not refunded, the commission is due as normal; and
• Panion’s share of a reserve fee (C4.2) is never credited.

C4.4 VAT. Every commission rate, including the reserve fee kept under C4.2, includes any VAT due; Panion never adds VAT on top. Until Panion is entered in the VAT register it charges no VAT and the rates apply as stated. From that date, on bookings made on or after 15 October 2026, the 2.42% rate becomes 3% including VAT on amounts collected from that date, and Panion’s invoice shows the VAT contained in the commission at the rate for the service (25%, 12% or exempt). Bookings made before 15 October 2026 keep the rate applied when they were made. The Provider is responsible for VAT and tax on its own sales to Customers.

C4.5 Monthly invoice. Panion issues one invoice per Provider legal entity per calendar month for the commission (including reserve fees kept) and any VAT, with a specification per booking, the commission credited for refunds (C4.3), the commission kept on bookings the Provider cancelled (C4.3 and C6.2), and credit notes for later corrections. Invoices are sent by email or, where the Provider can receive them, as electronic invoices (EHF).

C4.6 Settlement by deduction.Customer payments are settled to the Provider’s own SagaPay merchant account. The commission is collected through the payment split and deducted from the Provider’s SagaPay payout; the invoice shows the amounts already deducted. Any balance owed to Panion (for example commission on sales without a split, such as desk sales, or commission kept on a booking the Provider cancelled and refunded in full) is payable within 14 days of the invoice date. Commission credited under C4.3 is set off against amounts the Provider owes Panion, or paid to the Provider. Panion does not hold Customer funds and pays out no ticket revenue to the Provider.

C4.7 Discounts. Discounts (date pricing, group discounts and promo codes) are set up or agreed by the Provider and reduce the amount the Customer pays. Panion’s commission is calculated on the reduced amount.

C5. Insurance

The Provider must maintain at all times:

(a) liability insurance covering personal injury and property damage to Customers and third parties, with cover appropriate to the nature and risk of the Activity, and not less than NOK 10,000,000 where reasonably required by Panion; (b) any statutory insurance required for vehicles, vessels, animals or equipment used; (c) occupational injury insurance for staff.

Proof of insurance must be provided on request.

C6. Bookings, cancellations and no-shows

C6.1 A booking is binding for the Provider once confirmed in its booking system.

C6.2 If the Provider cancels a confirmed booking, the Customer is refunded in full from the Provider’s merchant account, including any reserve fee (C4.2). The Provider states the reason when it cancels:

• Weather, force majeure or genuine safety reasons (for example storm, closures, strikes or government measures, or conditions that make the Activity unsafe): the commission on the refunded amount is credited to the Provider (C4.3). Panion keeps only the reserve fee.
• Any other reason(for example overbooking, no guide or staff available, technical faults, too few participants, or the Provider’s own decision): Panion keeps its full commission on the booking (C4.3), and the Provider bears it in addition to refunding the Customer in full.

A cancellation made in the Provider’s own booking system without a reason is treated as one for weather, force majeure or safety until the Provider or Panion classifies it. Panion may classify a cancellation as one for another reason when the facts show it, and tells the Provider through its reporting. The Provider also bears any direct costs Panion incurs because of the cancellation (for example transaction fees), unless the cancellation is caused by weather, force majeure or genuine safety reasons.

C6.3 Customer cancellations follow the cancellation rules the Provider set for the Activity. Where a card refund is no longer possible, the Provider refunds the Customer by bank transfer.

C6.4 If an Activity cannot take place because of force majeure, the Customer chooses between a new date and a full refund, including any reserve fee, which the Provider pays as set out in C4.2 (B8).

C6.5 A Customer no-show counts as a delivered booking, and the commission is due.

C7. Sales at the Provider's desk

Card or cash sales the Provider makes at its own fixed sales desk or counter are the Provider’s own cash sales (kontantsalg). The Provider must register them in its own certified cash register system (kassasystem) and give the receipt required by law. Panion does not supply a cash register system. Commission on desk bookings made through the Platform is invoiced under C4.

C8. Customer complaints and claims

C8.1 The Provider handles complaints about the Activity as the Customer’s contracting party. Panion passes on complaints it receives and may help with the communication.

C8.2 The Provider bears Customer claims about the Activity (price reduction, refund, re-performance, compensation), including reasonable handling costs Panion incurs.

C9. Direct contact with Customers

After a booking is confirmed, the Provider may contact the Customer directly with practical information needed to deliver the Activity. The Provider must not use Customer data to market its own or third-party services without the Customer’s separate consent, or where marketing law otherwise does not allow it.

C10. Personal data

C10.1 Bookings on panion.travel and through Panions’ links. Panion and the Provider each act as independent controllers for the Customer personal data exchanged about these bookings, as described in the Privacy Policy. Panion shares the data needed to deliver the Activity (name, contact details, number of participants, special needs), and the Provider may use it only to deliver the Activity, comply with legal obligations and answer the Customer.

C10.2 Bookings through the Provider’s own channels. For bookings the Provider takes through its own channels using the Panioncheckout (the checkout embedded on the Provider’s own website, hosted checkout links, payment links and desk bookings), the Provider is the controller and Panionprocesses the booking data as the Provider’s processor, under the data processing agreement in Annex 1. Annex 1 is part of these Terms and is accepted with them.

C10.3 For Customer data received from Panion under C10.1, the Provider must implement appropriate security measures, notify Panion without undue delay of any personal data breach involving that data, help Panion answer data subject requests, and not transfer the data outside the EEA without an appropriate transfer mechanism.

C11. Platform tax reporting (DPI)

C11.1 Panionmay be a reporting platform operator under the Norwegian rules on digital platform information (skatteforvaltningsloven § 7-11, “DPI”, based on the EU’s DAC7). Panionmay then report information about the Provider and the consideration it received through the Platform to the Norwegian Tax Administration, which may share it with other countries’ tax authorities. Panion will send the Provider a copy of what is reported.

C11.2 On request, the Provider must give Panion the information the rules require, including legal name, organisation number, VAT number, registered address, country of tax residence, the payout account identifier and, for accommodation, the address and land register number (gnr/bnr) of each property and the days it was rented.

C11.3 If the Provider does not provide the information within the period the rules allow after two reminders, Panionmay suspend the Provider’s listings until it does.

C12. Liability and indemnity

C12.1 The Provider is liable to Panion for, and shall indemnify Panion against, any claim brought against Panionby Customers, public authorities or third parties that arises from: (a) the Provider’s performance or non-performance of the Activity; (b) inaccurate or misleading information provided by the Provider; (c) failure to meet safety, insurance, tax or compliance requirements; (d) personal injury, death or property damage caused by the Provider, its staff or subcontractors; (e) infringement of third-party rights in content uploaded by the Provider.

C12.2 Panion’s total liability towards the Provider is limited to the commission Panion received from the Provider in the 12 months before the event giving rise to the claim. This limit does not apply to wilful misconduct or gross negligence.

C12.3 Neither party is liable for indirect or consequential losses, except in cases of wilful misconduct or gross negligence.

C13. Termination of the Provider relationship

C13.1 Either party may terminate the Provider relationship with 14 days’ written notice (email is sufficient).

C13.2 Bookings already confirmed at termination must be delivered on the agreed terms unless otherwise agreed, and commission on bookings made before termination remains due.

C13.3 Panion’s right to suspend or close a Provider account is set out in Section E6.

D1. Role

Panions publish curated lists of Activities and refer Customers to the Platform through a unique link or QR code. Panions do not sell the Activities and are not party to the contract between the Customer and the Provider. A Panion acts as an independent business: as a self-employed person or a company, not as an employee of Panion.

D2. Acceptance

A Panion accepts these Terms by creating a Panion account or by publishing a Panion referral link or QR code.

D3. Commission

D3.1 A Panion may earn a commission on each completed booking attributed to its link or QR code, at the rate shown in the Panion account at the time of booking. The commission is paid by Panion out of its own commission and never changes the price the Customer pays.

D3.2 Panion makes no promise about the level of bookings, traffic, conversion or commission a Panion will earn. Examples and estimates are illustrative only. There is no fixed remuneration or minimum payout.

D3.3 A booking is attributed to the Panion whose link or QR code the Customer used before booking, within the attribution window stated in the Panion account (typically 30 days). Panion is not liable for attribution failures caused by browser settings, ad blockers, declined cookies or other factors outside its reasonable control.

D3.4 Commission for a month is paid to the payout account registered in the Panion account after Panion has issued the self-billed invoice for that month (D4.1) and the Panion has provided the details in D4.2, subject to Section E7. No commission is payable for cancelled, refunded, charged-back or fraudulent bookings.

D3.5 Panionmay change commission rates or attribution rules with 30 days’ notice through the Panion account. New rules apply to bookings made after they take effect.

D4. Self-billing agreement and tax

D4.1 Panion and the Panion agree that Panionissues the invoice for the Panion’s commission on the Panion’s behalf (self-billing, selvfakturering). Each month Panionissues a numbered self-billed invoice in the Panion’s name, with the bookings, the commission and any VAT, and makes it available in the Panion account. The Panion accepts these invoices, must not issue its own invoice for the same commission, and must report any error within 14 days.

D4.2 Before commission is paid, the Panion must provide its legal name, organisation number (or, where it has none, national identity or D-number), address, country of tax residence, whether it is registered for VAT, and payout details, and must keep them up to date. Where the Panion is VAT-registered, VAT is added to the self-billed invoice.

D4.3 The Panion is responsible for reporting and paying its own tax and VAT on commission income. Panion may report payments to the tax authorities where the law requires it. Where the law treats a payment as pay for work, or the Panion has no organisation number, Panionwithholds tax, reports it and pays employer’s contributions as required, and pays the net amount.

D4.4 Either party may end the self-billing agreement with 30 days’ notice; commission is then paid against the Panion’s own invoice.

D5. Conduct

The Panion shall:

(a) present Panion and the Activities truthfully and without misleading anyone; (b) not use Panion’s brand or trademarks beyond the materials provided; (c) not engage in spam, paid search bidding on Panion-branded keywords, or conduct that breaks marketing or consumer law (including markedsføringsloven); (d) clearly disclose to its audience that it may earn commission on referrals.

D6. Termination

D6.1 Either party may terminate the Panion relationship with 30 days’ written notice.

D6.2 Panion’s right to suspend or close a Panion account is set out in Section E6.

E1. Use of the Platform

No user may misuse the Platform, including by attempting unauthorised access, scraping, or posting unlawful content. Panion may suspend or terminate access for violations.

E2. Intellectual property

All content on the Platform (text, design, logos, code) is owned by Panion or its licensors and may not be copied or used without written consent, except as permitted by law or by these Terms (for example the licence granted by Providers in C2.4).

E3. Confidentiality (Providers and Panions)

Providers and Panions shall keep commercial, technical and financial information received from Panion confidential, except where the information is public or must be disclosed by law. This obligation survives termination for 3 years.

E4. Force majeure between businesses

Between Panion, Providers and Panions, neither party is liable for failure to perform caused by extraordinary circumstances outside its reasonable control, including extreme weather, natural events, pandemic, strikes or government action. Customers’ rights in such cases are set out in B8.

E5. Notices

Notices to Panion may be sent to hello@panion.travel. Notices to users are sent to the email address registered in the user’s account or, for Customers, the email used when booking.

E6. Suspension and closure of Provider and Panion accounts

E6.1 In addition to the termination rights in C13 and D6, Panion may suspend, restrict or close a Provider or Panion account, without prior notice where the situation requires it, in case of: (a) actual or suspected breach of these Terms; (b) actual or suspected fraud or other unlawful conduct; (c) conduct that could harm Customers, other users, the Platform or Panion’s reputation; (d) requests from public authorities or court orders; (e) missing tax information under C11 or D4; (f) discontinuation of the Platform or the relevant service.

E6.2 Panion will give reasons where reasonably possible. Where a Provider account is suspended or closed, confirmed bookings are normally honoured to protect Customers. If Panionreasonably considers that this is not in the Customers’ interest, the bookings may be cancelled and the Customers refunded in full by the Provider, including any reserve fee (C4.2).

E6.3 Suspension or closure gives no right to compensation, lost profits or lost commission, except as required by mandatory law.

E7. Set-off and withholding

E7.1 Panion may withhold or set off amounts owed to a Provider or Panion where: (a) there is a pending refund, chargeback, complaint or dispute relating to a booking; (b) Panion reasonably suspects fraud, error or breach of these Terms; (c) the account is suspended under E6; (d) the law, a court or a public authority requires it; (e) payout or identity details cannot be verified; (f) the Provider or Panion owes Panion money (including commission, VAT, costs under C6.2 and C8.2, and chargeback costs).

E7.2 Withheld amounts are released when the underlying issue is resolved. No interest is paid on withheld amounts, except where required by mandatory law.

E8. Governing law and venue

These Terms are governed by Norwegian law. Disputes between Panionand Providers or Panions are brought before the ordinary Norwegian courts, with Nord-Troms og Senja tingrett as the agreed venue. Customers’ rights are set out in B15.

DPA 1. Scope, subject matter and duration

DPA 1.1 This DPA applies to the personal data Panion processes for bookings the Provider takes through its own channels using the Panioncheckout (C10.2): the checkout embedded on the Provider’s own website, hosted checkout links, payment links and desk bookings. It does not apply to bookings on panion.travelor through Panions’ links, where each party is an independent controller (C10.1).

DPA 1.2 The subject matter is the processing needed to take, pay for, confirm, change, cancel and refund those bookings, and to give the Provider the related reporting, invoicing basis and support.

DPA 1.3 This DPA applies for as long as the Provider uses the Panion checkout, and after that until the data is deleted or returned under DPA 10.

DPA 1.4 Panion acts as an independent controller only for the data it must keep for its own legal obligations, such as bookkeeping of its commission, platform tax reporting (C11) and preventing fraud on its payment flows.

DPA 2. Nature and purpose, data and data subjects

DPA 2.1 Nature and purpose. Panioncollects booking data through the checkout, stores and structures it, sends it to the Provider’s booking system and to the payment service provider, sends booking confirmations, receipts, reminders and messages in the Provider’s name, shows the bookings in the Provider’s reporting, helps with support, and deletes the data. The purpose is to deliver the checkout and booking service to the Provider. Panion does not use the data for its own purposes, except as stated in DPA 1.4.

DPA 2.2 Types of personal data.The Customer’s name, email address, phone number, country and language; the number and names of participants; the booking (Activity, date, time, price, pickup and other details); special needs or requests the Customer chooses to give, which can include health data such as allergies or mobility needs; payment data (transaction references, card brand, the last four digits and the expiry date of the card; full card numbers are handled by the payment service provider and never stored by Panion); messages with the Customer; and technical data from the checkout (IP address and device).

DPA 2.3 Data subjects.Customers who book through the Provider’s own channels, the participants named in a booking, and contact persons the Customer gives.

DPA 3. Instructions

Panionprocesses the data only on the Provider’s documented instructions, including for transfers outside the EEA, unless EEA or Norwegian law requires otherwise; Panionthen tells the Provider before processing, unless that law forbids it. These Terms, the settings the Provider chooses on the Platform and the Provider’s written requests (email is sufficient) are the Provider’s instructions. Panion tells the Provider without delay if, in its opinion, an instruction breaks the GDPR or other data protection law. The Provider is responsible for having a lawful basis for the processing and for informing its Customers.

DPA 4. Confidentiality

Panion ensures that everyone it authorises to process the data has committed to confidentiality or is under an appropriate statutory duty of confidentiality, and gives access only to those who need it for their work.

DPA 5. Security

Panion implements the technical and organisational measures required by Article 32 GDPR, appropriate to the risk, including:

• encryption of data in transit (TLS) and encryption at rest by the hosting providers;
• encrypted storage of the card tokens used for pay-later bookings, and card data handled only by the payment service provider;
• access control by role, with database rules that limit each Provider’s team to its own bookings;
• logging and error monitoring, and backups of the database; and
• regular review of the measures as the Platform changes.

DPA 6. Sub-processors

DPA 6.1 The Provider gives Panion general authorisation to use sub-processors. At the date of this version, Panion uses:

• Supabase, Inc.: database, user accounts and file storage for the Platform
• Vercel, Inc.: hosting of the Platform, with application servers in the EU (Stockholm, Sweden)
• Cloudflare, Inc.: content delivery, network security and hosting of parts of the Platform
• SagaPay (Surfboard Payments): payment processing on the Provider's merchant account, card payments, stored cards for pay-later bookings and refunds
• Loops (Loops.so, Inc.): booking confirmations, reminders and other booking emails
• Resend (Plus Five Five, Inc.): delivery of system emails
• Functional Software, Inc. (Sentry): error monitoring, with data stored in the EU (Germany)
• Twilio Inc. and Meta Platforms Ireland Ltd. (WhatsApp Business): text and WhatsApp messages to Customers, only when the Provider turns them on

DPA 6.2 Panion tells the Provider by email or on the Platform at least 14 days before it adds or replaces a sub-processor. The Provider may object on reasonable data protection grounds within that period. If the parties cannot agree, the Provider may end the Provider relationship under C13 without cost.

DPA 6.3 Panionimposes on each sub-processor, by contract, data protection obligations that are no less protective than this DPA, and remains responsible to the Provider for the sub-processor’s performance.

DPA 6.4 The Provider’s own booking system (for example Bókun), and any analytics or advertising account the Provider connects (for example its own Meta pixel), receive booking data on the Provider’s instruction. They are the Provider’s own suppliers, not Panion’s sub-processors.

DPA 7. Assistance

DPA 7.1 Taking into account the nature of the processing, Panion assists the Provider by appropriate technical and organisational measures in answering requests from data subjects exercising their rights under Chapter III GDPR. Panion forwards to the Provider, without undue delay, any such request it receives about this processing, and does not answer it itself unless the Provider asks it to.

DPA 7.2 Panion assists the Provider in meeting its obligations under Articles 32 to 36 GDPR (security, breach notification, data protection impact assessments and prior consultation), taking into account the nature of the processing and the information available to Panion.

DPA 8. Personal data breaches

Panion notifies the Provider without undue delay after becoming aware of a personal data breach affecting the data, with the information Article 33(3) GDPR requires as far as it is available (in stages where needed), and takes reasonable steps to contain the breach and limit its effects. The Provider is responsible for notifying the supervisory authority and the data subjects where required.

DPA 9. Transfers outside the EEA

Paniontransfers the data outside the EEA, or allows a sub-processor to do so, only where Chapter V GDPR is met: an adequacy decision (including the EU-US Data Privacy Framework for certified recipients) or the EU Commission’s Standard Contractual Clauses (Decision (EU) 2021/914), with supplementary measures where needed. Several of the sub-processors in DPA 6.1 are established in the United States and rely on these mechanisms.

DPA 10. Deletion or return at the end

When the Provider relationship ends (C13), the Provider may export its bookings from the Platform and may ask Panion in writing, within 30 days, to return the data. Panion then deletes the data processed under this DPA, including copies, within 90 days of the end, unless EEA or Norwegian law requires Panion to keep it (for example accounting records under the Norwegian Bookkeeping Act); such data is kept only for that purpose and as long as the law requires. Backups are overwritten in the normal backup cycle.

DPA 11. Information and audits

Panion makes available to the Provider the information needed to demonstrate compliance with Article 28 GDPR and this DPA, and allows for and contributes to audits, including inspections, by the Provider or an auditor it mandates who is bound by confidentiality. Panion may first answer with written information and documentation. An audit is announced at least 30 days in advance, takes place during normal working hours, is limited to the processing under this DPA and does not take place more than once a year, unless a personal data breach or a supervisory authority requires it. Each party bears its own costs.

DPA 12. Liability and term

Liability under this DPA follows C12, except where mandatory law, including Article 82 GDPR, provides otherwise. This DPA ends when Panion no longer processes personal data for the Provider under it; DPA 10 and DPA 11 continue to apply until then.