GENERAL TERMS AND CONDITIONS OF THE RECIQLO PLATFORM AS OF 10/21/2025
1. Definitions
1.1. In these General Terms of Use (hereinafter: Terms), the defined terms:
“Company” shall mean RECIQLO DOO BEOGRAD, Tax ID: 115347447, Registration Number: 22145061;
“Waste Management Act” means the Waste Management Act (“Official Gazette of RS”, No. 36/2009, 88/2010, 14/2016, 95/2018 – other law and 35/2023);
“Waste Holder” is the waste producer, natural or legal person, or entrepreneur who has actual control over the waste in accordance with the Waste Management Act, and who advertises waste through the Platform, with the aim of transferring possession of the waste to the Buyer;
“Waste” means any substance or object that the waste holder discards, intends to discard, or is required to discard;
“Reciqlo Platform” or “Platform” is software managed by the Company for advertising waste for sale or the need to transfer waste possession for a fee to the User who takes over the waste, through which waste holders and persons interested in advertised waste can make contact and conclude a contract whereby, in accordance with the Law, the waste holder transfers possession of the waste, and which is available to Users via the website reciqlo.ai or the Reciqlo mobile application;
“Buyer” is a legal entity or entrepreneur, a User on the Platform who conducts waste management activities fully in accordance with the regulations of the Republic of Serbia, which allows them to take over waste from waste holders.
“User” means any legal entity, entrepreneur with headquarters in the Republic of Serbia, registered in accordance with applicable law, or natural person with residence or temporary residence in the Republic of Serbia, who creates a user account for the Platform regardless of whether they use any Services offered by the Company through the Platform, and regardless of whether they use them as a Waste Holder or as a Buyer;
“Terms” shall mean these General Terms and Conditions, with all their constituent parts and attachments, and future amendments;
“Services” shall mean any and all services that the Company may provide to Users or third parties, including, without limitation, the Internet Service Usage Service, and any services that the Company begins to provide after the date these Terms take effect;
“Internet Service Usage Service” shall mean all Company services that it provides to Users through the Platform; “Website” shall mean the website reciqlo.ai, with all content available on it, including the Platform. Any reference to the Website made in these Terms shall also be considered a reference to the Platform, including the mobile application where the Platform is located.
2. Acquiring User Status and Basic Terms of Website and Platform Use
2.1. User status is acquired by (1) creating a user account to use the Platform on the Website, by submitting the required data for this purpose, and (2) accepting these Terms through the Platform, whereby such person and the Company enter into a contractual relationship governed by these Terms. No person shall be considered a User or user of the Services provided by the Company until such person and the Company enter into a contractual relationship by accepting these Terms through the Platform.
2.2. These Terms have been made available in a timely manner to the person who has proceeded to create a user account, and they have been enabled to study these Terms before entering into a Contractual relationship with the Company for the purpose of using the Platform.
2.3. The Company reserves the right, but has no obligation, in case of doubt regarding the identity of the person who created the user account and/or the rights regarding the representation of the person creating the user account on behalf of a potential User who is a legal entity, even after acceptance of these Terms by such persons, to condition entering into contractual relations with the Company by concluding a special agreement on Platform use in the form of an electronic document using a qualified electronic signature in accordance with the Law on Electronic Document, Electronic Identification and Trust Services in Electronic Business.
2.4. After creating a user account and accepting the binding application of these Terms, the Company will have the right to verify, to the extent permitted by the regulations of the Republic of Serbia, the identification data collected from the person during the creation of the user account, and the Company reserves the right to, for justified reasons, terminate the contractual relationship regarding Platform use, which reasons include the Company’s knowledge that such person has unauthorized created a user account or knowledge of intended abuse. These reasons for unilateral termination are additional to other reasons for unilateral termination provided for in these Terms.
2.5. The User declares and guarantees that all data submitted to the Company when creating the user account are true and correct, and that such user account was created by a person who is authorized by the authorized representative of the User who is a legal entity to take such action.
2.6. Upon accepting these Terms and entering into contractual relations with the Company, the User will be notified via email that they have entered into such a contractual relationship. However, regardless of such notification, the Company’s records (logs) showing that the User, after creating a user account, accepted these Terms will be considered sufficient proof of entering into contractual relations with the Company. The Company will, at the User’s request, provide the User with an excerpt from such records.
2.7. When creating a user account, the User will be required to enter the requested data into the registration form available on the Platform, and to fully comply with all requirements regarding keeping access data confidential, in order to prevent access to such data by unauthorized third parties, in order to avoid abuse. If the User, at any time, suspects that an unauthorized third party has learned such data, they must immediately notify the Company and change the data immediately. If third parties use the User’s account with the User’s consent, this will in no way release the User from the responsibilities and obligations provided for in these Terms. The Company will not be liable for any damage that occurs as a result of inadequate keeping of access data confidential by the User. The User agrees to compensate the Company for any damage that may occur to the Company, or its representatives and employees (including due to proceedings of administrative and other bodies of the Republic of Serbia, and due to court or other proceedings initiated by third parties, including other Users) due to unauthorized use of their account by a third party due to violation of this provision by that User.
2.8. By accepting these Terms, and entering into contractual relations with the Company regarding the use of the Platform, and creating an account on the Platform, the User accepts that when accessing the content of the Website or Platform, the provisions of these Terms bind them without limitation. If the User does not agree with this, they need to deactivate their user account on the Platform and refrain from accessing the Website contents. However, if the User uses any Services of the Company, the User will not be released from their obligations under the contractual relationship concluded with the Company regarding the provision of these Services by the mere fact that they have deactivated their user account. Also, if the User deactivates their user account during the process of contracting business regarding possession of waste through the Platform in which they act as a Waste Holder or Buyer, they will be obliged to compensate the Company, as well as the person or persons with whom they participate in the contracting process, for any damage that may occur due to deactivating the account during such process.
2.9. Unless explicitly regulated otherwise in these Terms, the Website and its entire content, including without limitation, the Platform, any and all texts, logos, graphic solutions, images and any other digital material found on the Website and Platform, except those posted by the User themselves, are copyrighted work and property of the Company or are posted on the Website with permission from the owner or authorized rights holder.
2.10. The User retains copyright over individual text and photographs of their advertisements. The User agrees to the insertion of a watermark by Reciqlo in each of the photographs they attach when posting advertisements, as well as to the processing of photo dimensions for their aesthetic fitting into the appearance of the Reciqlo Website and Platform.
2.11. Any abuse of the Website and Platform is prohibited.
2.12. Any form of public display, transmission, modification, or any form of use of any part of the Website and Platform content is prohibited without prior express written permission from the owner of the subject content on the Website and Platform or other owners of copyright or other intellectual property rights.
2.13. The User will refrain from any violation of any rights related to the content on the Website and Platform, and the Company will protect its copyrights, intellectual property rights and other related and other rights (whether they belong to the Company or the Company uses them with consent, contractual or otherwise, of the lawful holder of such rights), to the greatest extent permitted by law.
2.14. Despite the Company’s efforts to keep the content on the Website and Platform current, complete and accurate, the Company does not guarantee the completeness, correctness, currentness and constant availability of the Website and Platform, and the User agrees not to rely on the completeness, correctness, currentness of content on the Website and Platform. The User agrees that the Company’s liability for any errors and omissions regarding the Website content is entirely excluded to the extent permitted by law, and that the Company will not be liable for any damage that occurs due to said errors and omissions. In this regard, by using the content of the Website and Platform, the User accepts all risks that arise from using them and accepts to use the content of the Website and Platform exclusively for their own use and at their own risk.
2.15. A User who posts any content on the Platform, including, without limitation, any identification data, data about waste they advertise, documents related to such waste, waste photographs, commercial conditions for transfer of possession of waste, is fully responsible to the Company for the content of such data and guarantees, under material and criminal liability that such data is true and complete and not misleading. In this regard, the User agrees to compensate the Company for any damage that may occur to the Company, or its representatives and employees (including due to proceedings of administrative and other bodies of the Republic of Serbia, and due to court or other proceedings initiated by third parties, including other Users) due to violation of this provision by that User.
2.16. The User is obliged during the account creation process, or when entering data, to enter accurate and complete data, including, if applicable, personal data, and in relation to this data gives explicit consent to the Company to process and store it for the purposes of executing its obligations related to the Services or its legally based obligations and prevention of potential abuse, whereby the Company’s Privacy Policy, which forms an integral part of these Terms, fully applies to the relations between the User and the Company regarding personal data protection, and by agreeing to these Terms, the User also agrees to the Privacy Policy and confirms that they have read and understood it.
2.17. The Company undertakes to use all documentation and data, including personal data obtained from the User, as well as any photographs, exclusively for the purpose of providing the Service it provides for the User (solely for example, for a User for whom the Company provides the Internet Service Usage Service, personal data obtained from the User will be used exclusively for preparing the text of the contract that such User as a Waste Holder will conclude with the Buyer) and will keep all information as a business secret. The obligations from this provision do not cease upon termination of these Terms and/or the contractual relationship between the User and the Company.
2.18. The Company undertakes to process personal data of the User, or third parties, for the purposes of executing any Service, in accordance with the Personal Data Protection Act, the European Union General Data Protection Regulation No. 2016/679 (GDPR) and other applicable regulations in the field of personal data protection. A User who accesses personal data related to other Users undertakes to fully comply with these regulations, in accordance with the capacity in which they access such data.
2.19. The Company undertakes not to process personal data it collects for the purpose of providing the Service for other purposes, unless those purposes are specified in the Privacy Policy.
2.20. The method of data processing and storage, as well as the duration of data storage, is explained in the Privacy Policy.
2.21. The legal basis for data collection and processing is specified in the Privacy Policy.
2.22. By accepting these Terms, the User confirms that they agree with and are familiar with the Privacy Policy, which regulates the legal basis, purpose of personal data processing, rights of data subjects and other aspects of personal data processing.
2.23. The Company may at any time, without notice, except regarding content posted on the Website by the User themselves, change the content on the Website or adjust the operation of the Website, or update the entire content of the Website in accordance with the Company’s needs or requirements of applicable regulations, and the Company reserves the right to modify the Website content at any time. There is no obligation for the Company to always keep the content on the Website current, nor does the Company take responsibility for consequences that may arise due to these changes.
2.24. The Company does not assume responsibility for the contents and availability of third-party websites that can be accessed via external links present on the Website, nor does it in any way guarantee the content of third-party websites. In case the Company provides Services related to data made available to Users through the Platform, the Company will inform the User about the owner of such data on the Platform itself.
2.25. Although the Company makes best efforts to protect the Website using the most modern methods of protection against viruses and other malicious and harmful software, the Company does not guarantee their complete absence. Therefore, the Company directs the User to take necessary protection measures such as using their own antivirus programs.
2.26. Communication between the Company and the User regarding the exercise of rights and obligations specified in these Terms, including, without limitation, regarding the use of the Website or Services, can validly take place electronically (through the Platform, email or other means of electronic communication, in full accordance with instructions that the Company gives to the User on the Platform or in direct communication with the User).
3. Buyer Status and Obligations
3.1. A User who intends to use the Platform as a Buyer is aware that, in accordance with the regulations of the Republic of Serbia, waste management activities can only be carried out by legal entities or entrepreneurs who, in accordance with the regulations of the Republic of Serbia, and especially the Waste Management Act, possess a valid permit for performing such activities, and in this regard agree that they will participate in work on the Platform in the capacity of persons entering into contractual relationships with Waste Holders only if they meet the conditions for performing such activities. Despite the fact that the Company will, when creating a user account and contracting procedures with other Users, reasonably perform necessary checks in this regard, the Company has no obligation, nor will it be obliged to monitor whether the User who has made an offer regarding taking possession of waste has met these conditions when submitting such offer, as well as whether such User at any time after making such offer continues to meet these conditions in accordance with the regulations of the Republic of Serbia. A User who acquires Buyer status agrees to compensate the Company for any damage that may occur to the Company, or its representatives and employees (including due to proceedings of administrative and other bodies of the Republic of Serbia, and due to court or other proceedings initiated by third parties, including other Users) due to unauthorized negotiation or contracting of business with other Users regarding waste in violation of this provision or regulations of the Republic of Serbia governing waste management.
3.2. In case after acquiring Buyer status, the User ceases to meet any statutorily determined conditions for persons performing waste management activities, they are obliged to notify the Company about this without delay.
3.3. The Company reserves the right to revoke a User’s Buyer status in cases of attempted or executed abuse by the Buyer on the Platform, in case of non-fulfillment of the Buyer’s obligations to the Company, as well as in other cases of violation of these Terms.
4. Advertising
4.1. Any User who is a Waste Holder can post an ad offering the waste they hold for another User to take possession of (with or without compensation, depending on the case, and in accordance with the Waste Management Law), regardless of the legal basis on which the Waste Holder holds such waste.
4.2. A User (Waste Holder) who wants to advertise waste on the Platform will be required to follow the advertising instructions on the Platform, and enter relevant data about the waste through the Platform, as well as upload photos or other data that describe the waste in detail. The User can enter any data related to the waste, either in specific fields provided by the Platform or in free-form fields intended for this purpose, which can serve to provide comprehensive information about the waste.
4.3. The Company does not verify the accuracy and completeness of data or graphical representations (including photos) that the User as a Waste Holder posts on the Platform for advertising purposes, and does not guarantee the completeness, correctness, currentness, and accuracy of such data. The Buyer, and any other User, agrees that making an offer regarding the transfer of possession of such waste is done at their own risk, not relying on such data or graphical representations as if given by the Company, but solely relying on them as data and graphical representations provided by the Waste Holder. The User agrees that the Company’s liability for any errors, inaccuracies, deceptions, and omissions related to the content of data posted on the Platform by the Waste Holder is entirely excluded to the extent permitted by law, and that the Company will not be liable for any damage resulting from these errors, inaccuracies, deceptions, and omissions, and agrees that any claim in this regard may be directed exclusively to the relevant Waste Holder. In this regard, the Buyer accepts all risks arising from the use of data and graphical representations made available by the Waste Holder, and accepts that any legal or other claim in this regard can be directed exclusively to the Waste Holder in question, and not to the Company.
4.4. By accepting these Terms, the Waste Holder guarantees and declares to the Company and other Users who have access to the Waste Holder’s ad:
- The advertised waste exists, the User is the Waste Holder and can dispose of the waste without restrictions, or has not already disposed of the waste through any legal transaction;
- The content of the ad and each of its parts is truthful and complete, and is not misleading in any respect;
4.5. Ads posted by Users must comply in all respects with the Advertising Law of the Republic of Serbia and the Copyright and Related Rights Law. Any ad that does not comply with the Advertising Law and the Copyright and Related Rights Law will be deleted from the Platform, with notification to the User who posted such an ad.
4.6. If the law prescribes that the activity within which the subject of advertising can be performed only on the basis of consent, permission, or other act of a state body, it is prohibited to advertise if consent, permission, or other act of the competent authority has not been issued.
4.7. It is not allowed to post ads containing untruths and lies, which may mislead anyone, offend anyone, cause harm to anyone, or take advantage of anyone’s gullibility.
4.8. It is not allowed to post identical or similar ads multiple times (so-called “spamming”). Similar ads are those that have the same subject of sale. Also, it is not allowed to post similar or identical ads from different accounts.
4.9. It is not allowed to insert URL links of companies, online stores, social media accounts (Facebook, Instagram, TikTok, etc.) or other websites (especially competitive ones) in the text (description) of the ad, information in ads, or in the account name.
4.10. It is not allowed to post photos that contain graphic editing for special emphasis, or contain logos of companies and other internet portals. In photos posted with the ad, it is not allowed to show faces of people or details that can lead to identification of persons or locations where the subject of the ad is located.
4.11. Automated or software-based ad posting is not allowed.
4.12. The Waste Holder confirms that the process of collecting offers for concluding a contract with them regarding the change of possession of the waste, after the waste is advertised on the Platform (“Advertised Waste”), will be carried out through the offer collection procedure on the Platform, and undertakes to fully respect and follow the instructions provided to them in this regard through the Platform, or via email or other means of communication.
4.13. The Waste Holder who advertises waste will be charged a fee for such advertising, in accordance with the Company’s current Tariff, in the manner prescribed in the next section, and only in case of successful contracting of the transfer of possession of the waste. Only the initial advertising is free.
4.14. After the process of collecting offers for the Advertised Waste on the Platform has been initiated, the Waste Holder who advertised such waste will not have the right to interrupt or suspend such process, except in the case that the waste in question is partially or completely destroyed during the course of such process without the fault of the Waste Holder, about which the Waste Holder will notify the Company without delay, and no later than within 1 (one) day.
4.15. After the process for collecting offers on the Platform has been initiated, the Waste Holder will not have the right to negotiate the sale of the Advertised Waste outside the Platform or to directly communicate with potential Buyers until the process is unsuccessfully concluded. If the process is successfully concluded, which includes, among other things, that at least one of the Buyers has submitted an offer for the Advertised Waste and the Waste Holder accepts such offer, the Seller will be obliged to proceed with contracting with the Buyer and adhere to further instructions regarding the agreed method of taking possession of the waste.
5. Offer collection process and contract conclusion
5.1. Upon successful advertising of the Advertised Waste, Buyers will have the right to access basic information about the Advertised Waste through the Platform.
5.2. The Company does not verify the accuracy and completeness of all data or graphical representations (including photos) that the User acting as a Waste Holder posts on the Platform for the purpose of advertising waste, and does not guarantee the completeness, correctness, currentness, and accuracy of such data or graphical representations. The User acting as a Buyer agrees that the Company’s liability for any errors, inaccuracies, deceptions, and omissions related to the content of data posted on the Platform by the Waste Holder is entirely excluded to the extent permitted by law, and that the Company will not be liable for any damage resulting from these errors, inaccuracies, deceptions, and omissions, and agrees that any claim in this regard may be directed exclusively to the relevant Waste Holder. In this regard, the Buyer accepts all risks arising from the use of data and graphical representations made available by the Waste Holder, and accepts that any legal or other claim in this regard can be directed exclusively to the Waste Holder in question, and not to the Company.
5.3. During the offer collection process, the Buyer has the right to submit an offer to purchase the Advertised Waste in the form designated by the Platform. The Buyer will have the right to submit an offer that includes the price for the transfer of possession of the waste that they are willing to pay (if applicable) or the fee that such Buyer requires for the transfer of possession of the waste or performing another aspect of waste management activity. The proposed time for waste collection will also be an integral part of the offer.
5.4. All offers received from Buyers on the Platform regarding certain Advertised Waste will be forwarded to the Waste Holder who posted the relevant ad. The Waste Holder will have the right to independently, at their complete discretion, accept any of the received offers, or not accept any of the received offers.
5.5. In case the Waste Holder who is a natural person accepts any of the received offers (“Accepted Offer”), the Company will:
- Issue an adequate accounting document to the Buyer that will serve as the basis for payment of an amount equal to the sum of: (i) the price offered by the Buyer for the waste (“Price”), and (ii) the amount of the fee for the Company’s Services, in accordance with the Company’s Tariff (“Fee”);
- Upon receipt of the Price and Fee payment from the Buyer, deliver to the Buyer and Waste Holder through the Platform the text of the contract that will contain basic elements, including the names of the contracting parties, description of the waste, price or fee for the transfer of possession of the waste, waste location, and contact details of the Waste Holder, and both parties will be obliged to conclude such contract using the Platform’s functionalities;
- Within one day of receiving confirmation within the Platform that the Buyer has taken possession of the waste, which confirmation both the Buyer and Waste Holder will be obliged to perform using the Platform’s functionality (such as scanning special barcodes for this purpose, etc.), the Company will transfer the amount of the Price to the Waste Holder’s bank account. In case such confirmations are not received within the timeframe provided by the Platform’s functionalities, the amount of the Price and Fee will be returned to the Buyer, and the Company will not be considered responsible in any way for the occurrence of reasons due to which the waste collection did not take place, and the Buyer and Waste Holder will have the right to address only the other party and not the Company for the protection of their interests.
5.6. In case the Waste Holder who is a legal entity accepts any of the received offers (“Accepted Offer”), the Company will:
- Issue an adequate accounting document to the Buyer and Waste Holder that will serve as the basis for payment of the Fee to both Users for the Services provided, in accordance with the Company’s Tariff;
- Upon receipt of the Fee payment from the Buyer and Waste Holder, deliver to the Buyer and Waste Holder through the Platform the text of the contract that will contain basic elements, including the names of the contracting parties, description of the waste, price or fee for the transfer of possession of the waste, waste location, and contact details of the Waste Holder, and both parties will be obliged to conclude such contract using the Platform’s functionalities;
- Within one day of receiving confirmation within the Platform that the Buyer has taken possession of the waste, which confirmation both the Buyer and Waste Holder will be obliged to perform using the Platform’s functionality (such as scanning special barcodes for this purpose, etc.), the Company will deliver to the Waste Holder electronic versions of the documentation that the Buyer is obliged to provide to the Holder in accordance with the Waste Management Law. In case such confirmations are not received within the timeframe provided by the Platform’s functionalities, the amounts of the Fee will not be returned to the Buyer and Waste Holder, and the Company will not be considered responsible in any way for the occurrence of reasons due to which the waste collection did not take place, and the Buyer and Waste Holder will have the right to address only the other party and not the Company for the protection of their interests.
5.7. Every transaction between Reciqlo Users is at the User’s own risk. The Company will not bear any responsibility for any damage incurred during any transactions between Users. Users of the services are in any case called upon to exercise caution during mutual buying and selling.
6. Tariff
6.1. All fees charged by the Company to Users will be charged exclusively in dinars, to the account held by the Company at a commercial bank in Serbia.
6.2. The Company adopts a Tariff which provides for fees charged to Users. The Tariff is published on the Website and on the Platform.
6.3. The Company has the right to change the Tariff, whereby the Tariff that is valid at the time of providing the Service will always apply to the provided Service.
7. Final provisions
7.1. In case of any violation of these Terms, non-compliance with the stated restrictions in this text, or violation of the law by Users, it is possible to issue a warning, as well as temporary or permanent ban on the use of the user account. Depending on the severity and frequency of violations, the Reciqlo administration first issues a warning, and then may decide on temporary or permanent account blocking, although at its sole discretion it may immediately impose a measure of permanent account blocking. Users whose account is temporarily or permanently blocked are not entitled to any compensation for damages, as they could not use the Services during the blocking period. These measures can also be applied in cases where there was no violation of the Terms, to prevent damage or when certain actions or inactions of Users hinder the Company’s operations or the operation of the Platform.
7.2. These Terms are based on and interpreted in accordance with the law of the Republic of Serbia. Any disputes regarding the execution of Services or terms of use of the Website and Platform, the Company and the User will try to resolve amicably, and if this is not possible, the competent court in Belgrade will have jurisdiction to resolve the dispute. The Company and the User agree that in case of a dispute, the substantive and procedural law of the Republic of Serbia will apply as applicable.
7.3. For relations between the User and the Company that are not regulated by these Terms, the provisions of the Law on Obligations, the Law on Electronic Commerce, the Law on Personal Data Protection, and other relevant regulations of the Republic of Serbia apply.
7.4. All subsequent amendments and additions to these Terms must be published on the Website or on the Platform, indicating the date of the last update. The Company will be obliged to notify the User via email about amendments and/or additions to these Terms, and if the User does not agree with such amended or supplemented Terms, they will be obliged to notify the Company via email and deactivate their user account on the Platform. In case of such disagreement by a User to whom the Company is providing any Service at the time of disagreement, which includes without limitation the process of giving offers for the User’s Advertised Waste, the Terms that were in force before the amendments and additions with which the User disagrees will apply to the relations between the User and the Company regarding such Service, and this will not affect the obligations incumbent on the User regarding the Service, nor will the User, in such case, be released from their obligations even if they deactivate their user account on the Platform.
7.5. These Terms come into force on October 21, 2025.
