1. Merchant information

Legal entity name:

BalancePath d.o.o.

Registered address:

Bulevar Milutina Milankovića 7đ, 11070 Belgrade, Republic of Serbia

Company registration number:

22145215

Tax identification number (PIB):

115348099

Business activity:

Brokerage of online psychotherapy services and wellbeing services for companies

Website:

https://balancepath.space

Contact email:

info@balancepath.space

Contact phone:

+381 60 585 80 61

VAT status:

BalancePath d.o.o. is not a VAT payer.

2. Description of services, payment methods and currency of charge

The Platform allows users to browse profiles of licensed psychotherapists, book individual or couples therapy sessions, and register for workshops organised by therapists presented on the Platform.

Payment can be made:

• By payment card (VISA, MasterCard, Maestro, DinaCard, American Express) through the secure Monri Payments service in cooperation with Banca Intesa a.d. Belgrade; or

• By bank transfer (payment instructions are available on the Payment Instructions page).

Service prices are displayed on each therapist's profile and are set by the therapist for every currency offered. Details on the currency of charge and conversion are provided in section 7 — Statement on conversion.

3. Customer service contact

For all questions, booking changes, complaints and cancellations, the User may contact BalancePath customer service via the following channels:

Email:

info@balancepath.space

Phone:

+381 60 585 80 61

Address:

Bulevar Milutina Milankovića 7đ, 11070 Belgrade

4. Service delivery

All services available through the Platform are of electronic nature and are delivered exclusively online, without physical delivery.

Upon successful payment, the Platform system automatically generates and sends a unique session link to the email addresses of both the User and the Therapist. The session is held at the agreed time via that link.

For a successful session, the User is responsible for providing: a stable internet connection, a device with camera and microphone, and a quiet environment for the duration of the session.

Limitations: the service is available to users from any country. The User is responsible for verifying, prior to booking, that the use of psychotherapy services provided by the selected therapist does not conflict with the regulations of the country from which they access the Platform.

5. Payment and general terms of service use

1. By paying for the selected service, the User enters into a contractual relationship with the selected therapist, and not with the Platform Owner.

2. The Platform Owner does not provide psychotherapy services but exclusively mediates between the User and the therapists promoted on its Platform. The therapist specifically authorises the Platform Owner to collect payments from the User on behalf of and for the account of the therapist for the services rendered.

3. The price of the service, displayed on each therapist's profile, is determined by the therapist.

4. The Platform Owner cannot under any circumstances be held responsible for the quality of the service provided by the therapist, nor liable for any damage resulting from its use.

5. The Platform Owner verifies whether the therapist operates legally and holds all permits and legal approvals required to provide the services offered through the Platform, but is not legally responsible for the validity of those approvals.

6. The User releases the Platform Owner from all liability and responsibility for any claims, actions, losses or damages resulting from or related to the use of a therapist's service on this Platform.

7. The Platform Owner in no way has access to the sessions held by therapists with Users, nor does it monitor the communication taking place during such sessions.

8. The psychotherapists presented on the Platform have obtained, or are in the process of obtaining, psychotherapy licences in psychotherapy modalities approved by the national associations of their respective countries.

6. Cancellation, complaints and refunds

6.1. Cancellation of a session by the User

• If the User cancels a booked session at least 4 (four) days before the scheduled time, they are entitled to a refund of the paid amount, reduced by 16% of the paid amount to cover the cost of refund processing and card processing.

• If the User cancels a booked session less than 4 (four) days before the scheduled time, or fails to contact the therapist at the scheduled time due to their own fault, they forfeit the right to a refund.

• Cancellation of a workshop registration is subject to the same rules as cancellation of a session.

6.2. Failure of the therapist to deliver the service

If the User does not receive the selected and paid service from the therapist at the scheduled time due to the therapist's fault, the User shall immediately notify the Platform Owner by email at info@balancepath.space. The therapist is then required to deliver the service at another time agreed directly with the User. If the therapist also fails to deliver the service at the rescheduled time, the User is entitled to a full refund of the paid amount, without any deduction.

6.3. Complaint procedure

Complaints shall be submitted by email to info@balancepath.space, including:

• name and surname, email used during booking

• name of the therapist and date/time of the session

• a clear description of the reason for the complaint

• where possible, the transaction Authorization Code from the payment confirmation

BalancePath d.o.o. undertakes to respond to a complaint within the statutory period of no later than 8 days from the date the complaint is received.

6.4. Refund of funds (statement required by Monri Payments)

In the event of returns and refunds to a User who has previously paid with a payment card, in whole or in part, and regardless of the reason for the return, BalancePath d.o.o. is required to issue the refund exclusively via the VISA, MasterCard, Maestro, DinaCard and American Express payment methods, which means that, at the merchant's request, the bank will refund the amount to the cardholder's account.

7. Statement on conversion

Sva plaćanja biće izvršena u lokalnoj valuti Republike Srbije — dinar (RSD). Za informativni prikaz cena u drugim valutama koristi se srednji kurs Narodne banke Srbije. Iznos za koji će biti zadužena platna kartica biće izražen u lokalnoj valuti kroz konverziju u istu po kursu koji koriste kartičarske organizacije, a koji u trenutku transakcije ne može biti poznat. Kao rezultat ove konverzije postoji mogućnost neznatne razlike od originalne cene navedene na internet stranici.

All payments will be charged in Serbian currency – Dinar (RSD). The amount your credit card account will be charged for is obtained through the conversion of the price in Euro into Serbian dinar according to the current exchange rate of the Serbian National Bank. When charging your credit card, the same amount is converted into your local currency according to the exchange rate of credit card associations. As a result of this conversion there is a possibility of a slight difference from the original price stated in our web site.

8. Protection of confidential transaction data

When entering payment card details, confidential information is transmitted over the public network in encrypted form using the SSL protocol and PKI system, which currently represent state-of-the-art cryptographic technology. Data security during purchases is guaranteed by the payment card processor, Monri Payments, in cooperation with Banca Intesa a.d. Belgrade. At no point are payment card details accessible to our system.

9. Privacy Policy

On behalf of BalancePath d.o.o. we undertake to protect the privacy of all our users. We collect only the necessary, basic data about users and data required to operate and inform users in accordance with good business practice and with a view to providing a quality service. All user data is strictly safeguarded and accessible only to employees for whom such data is necessary in order to perform their duties. All BalancePath d.o.o. employees and business partners are responsible for upholding privacy protection principles.

9.1. Data we collect

• When booking a session / registering for a workshop: name, surname, email.

• When creating a user account: name, surname, email, password (stored in encrypted form).

• When paying by card: card data (number, CVV, expiry date) and the buyer details entered in the payment form (full name, email, address, city, ZIP code, country, phone number) are processed exclusively on Monri Payments' side, as part of the mandatory 3D Secure check required by the card-issuing bank. BalancePath does not store this data in its database — it is forwarded directly from the form to Monri at the moment of payment. We store only the transaction identifier and payment confirmation.

• Whenever you visit the Platform: we automatically receive from each HTTP request your IP address, browser type and version, operating system, page URL and the address you came from (referer). This data is an integral part of every HTTP request to any website.

9.2. Purposes for which we use data

• Delivery of sessions (booking, sending the link, reminders).

• Communication regarding the user account and the services provided.

• Issuing invoices and fulfilling statutory obligations (accounting, tax records).

• Resolving complaints and disputes.

• Measuring website traffic and improving the user experience.

• Measuring the effectiveness of marketing campaigns.

• Preventing abuse of the Platform (protection against automated bot requests and spam).

9.3. Who we share data with

• The therapist with whom you have booked a session (only name, surname, email and the chosen time slot).

• The payment processor Monri Payments and Banca Intesa a.d. Belgrade (to the extent necessary to process and record the card transaction).

• Competent state authorities, when expressly required by law.

• Technology service providers (Google Ireland Limited for Google Analytics 4; Cloudflare Germany GmbH for Turnstile anti-bot protection; Microsoft Corporation for Bing domain verification; Hetzner Online GmbH for hosting) — receive the IP address and browser type from the HTTP request, without your name, email or other personal identifiers.

• Meta Platforms Ireland Limited (Facebook/Instagram Pixel and Conversions API) — receives the transaction amount, currency, IP address and browser type for the purpose of measuring ad effectiveness. We do not send your name, surname, email or user account identifier.

Your personal data is not sold, rented or otherwise transferred to third parties for marketing purposes.

9.4. Data retention period

Data related to booked and delivered sessions is retained for as long as required by the Corporate Income Tax Act and the Accounting Act of the Republic of Serbia. Data related to a user account is retained until the user requests deletion of the account.

Tracking data is automatically deleted upon expiry of the retention periods set by third parties: Google Analytics 4 — 14 months; Meta Pixel and Meta Conversions API — up to 90 days; server logs — up to 90 days.

9.5. Your rights

In accordance with the Personal Data Protection Act of the Republic of Serbia, the User has the right to:

• request access to their personal data being processed,

• request correction of inaccurate or incomplete data,

• request erasure of data (right to be forgotten), except where statutory obligations require its retention,

• withdraw consent to processing at any time,

• file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia.

• Users residing in the European Union or EEA also have the right to lodge a complaint with the data protection authority in their member state (e.g. BfDI or the competent regional authority in Germany, CNIL in France, Garante in Italy). A list of competent authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

All rights are exercised by sending a request to info@balancepath.space.

9.6. Cookies

The Platform uses the following categories of cookies:

• Functional cookies — necessary for the operation of the site (remembering the logged-in session, language preference).

• Analytics and marketing cookies (Google Analytics 4: _ga, _ga_*; Meta Pixel: _fbp, optionally _fbc) — used for analysing site traffic, improving the user experience and measuring the effectiveness of BalancePath d.o.o. marketing activities. These cookies are set exclusively after the user's explicit consent via the Cookie Consent banner and can be withdrawn at any time via the "Cookie settings" link in the page footer.

• Strictly necessary anti-bot protection for the guest flow (Cloudflare Turnstile) — used exclusively during the therapy booking flow when the user is not signed in to their user account (the so-called guest flow). Users who are signed in to their account do not encounter this element on any page of the Platform. Unlike earlier cookie-based anti-bot solutions, Turnstile does NOT set cookies and does not store persistent identifiers about individual visitors — it performs a real-time assessment of the request based on technical HTTP signals (IP address, browser type) and discards them immediately. Under Art. 5(3) of the ePrivacy Directive, this processing is carried out solely within the scope of a service explicitly requested by the user (protection of the guest booking form against automated bot attacks) and therefore does not require prior consent via the Cookie Consent banner; nevertheless, we transparently inform users about it — both through this text and through an informational message below the Turnstile widget. Cloudflare Germany GmbH acts as our processor (Art. 28 GDPR) on the basis of the Cloudflare Data Processing Addendum, which is an integral part of Cloudflare's terms of service.

Users may withdraw consent for analytics and marketing cookies at any time via the "Cookie settings" link in the page footer, or in their browser settings. All Platform features — including card payment, session booking and access to therapy — remain fully available even without analytics and marketing cookies.

9.7. Data security

All data is transmitted encrypted via the SSL/TLS protocol. Access to the servers and database is granted only to authorised BalancePath d.o.o. personnel using secure credentials.

9.8. Legal basis for processing

The legal basis for processing your data is established by the provisions of the Serbian Personal Data Protection Act (ZZPL) and the EU General Data Protection Regulation (GDPR):

• Performance of a contract (Art. 12(1)(2) ZZPL / Art. 6(1)(b) GDPR) — for booking and conducting sessions, creating and maintaining a user account, and communication regarding the services provided.

• Legal obligation (Art. 12(1)(3) ZZPL / Art. 6(1)(c) GDPR) — for issuing invoices and keeping accounting records, in accordance with the Corporate Income Tax Act and the Accounting Act of the Republic of Serbia.

• Consent (Art. 12(1)(1) ZZPL / Art. 6(1)(a) GDPR) — for analytical and marketing cookies, Google Analytics 4 and Meta Pixel/Conversions API tracking. You provide consent through the Cookie Consent banner on your first visit to the Platform and may withdraw it at any time via the "Cookie settings" link in the page footer.

• Legitimate interest (Art. 12(1)(6) ZZPL / Art. 6(1)(f) GDPR) — for preventing abuse of the Platform (anti-bot protection via Cloudflare Turnstile), technical server logs (security and troubleshooting) and basic aggregated visit statistics. We balance our legitimate interest against your rights and limit it to the minimum necessary for the stated purposes.

9.9. International data transfers

Some technology partners with whom we share a limited set of data (primarily IP address, browser type and basic technical metrics) are based outside the European Union, predominantly in the United States of America:

• Google Ireland Limited (Google Analytics 4, Google Workspace) and Cloudflare Germany GmbH (Turnstile anti-bot protection) — transfer to the USA under the EU-US Data Privacy Framework (DPF) certification. Cloudflare processes data primarily in the EU/EEA, with any onward transfer to the USA additionally covered by Standard Contractual Clauses (SCC).

• Meta Platforms Ireland Limited (Facebook/Instagram Pixel, Meta Conversions API) — transfer to the USA under the EU-US Data Privacy Framework (DPF) certification.

• Microsoft Corporation (Bing webmaster tools verification) — transfer to the USA under the EU-US Data Privacy Framework (DPF) certification.

For partners not certified under the DPF framework, we apply the European Commission's Standard Contractual Clauses (SCCs) as an appropriate safeguard, in accordance with Art. 46 GDPR.

The hosting infrastructure is provided by Hetzner Online GmbH (company seat: Gunzenhausen, Germany), while the servers on which the Platform is physically hosted are located in Helsinki (Finland, EU/EEA). The payment processor Monri Payments d.o.o. is based in Croatia (EU). No special international transfer mechanism is required for any of these processing operations, as the data does not leave the EU/EEA area.

9.10. Special category of data — health data

The Platform facilitates the scheduling of psychotherapy sessions. The mere fact that a user uses the Platform may indirectly be considered information about mental health, which under Art. 17 ZZPL / Art. 9(1) GDPR constitutes a "special category of personal data".

The legal basis for processing such data is:

• Explicit consent of the user (Art. 17(2)(1) ZZPL / Art. 9(2)(a) GDPR), given by accepting the General Terms of Use when creating an account or booking a session.

• Provision of health care by persons bound by professional secrecy (Art. 17(2)(8) ZZPL / Art. 9(2)(h) GDPR) — for the content of communication with the therapist.

Important notice: the content of the psychotherapy sessions themselves (conversation, notes, recordings, materials) is not accessible to BalancePath as a technical intermediary. Sessions take place directly between the user and the therapist. Therapists are persons bound by professional secrecy and are responsible for processing the session content in accordance with their professional regulations.

9.11. Minors

The BalancePath Platform is not intended for persons under 18 years of age. We do not knowingly collect personal data of users under 18. If you are a parent or guardian and believe that your minor child has provided their data to BalancePath without your consent, please contact us at info@balancepath.space and we will delete the relevant data without delay.

9.12. Data Protection Officer (DPO)

BalancePath d.o.o., according to the criteria of Art. 56 ZZPL and Art. 37 GDPR (number of employees, scope and nature of processing), is not required to appoint a Data Protection Officer (DPO). All requests and questions regarding data protection can be sent to info@balancepath.space.

9.13. Effective date and amendments

This Privacy Policy takes effect on 10 June 2026. BalancePath d.o.o. reserves the right to update this document from time to time. The current version is always available at https://balancepath.space/terms-of-use#privacy-policy. We notify users of material changes (e.g. the addition of new categories of collected data or new technology partners) via a prominent notice on the Platform or by email.

10. Statement on VAT

BalancePath d.o.o. is not a VAT payer in accordance with the provisions of the Value Added Tax Act of the Republic of Serbia. VAT is not included in the service prices published on the Platform.

11. Copyright

1. The Platform Owner retains copyright in all its own content (texts, images, video and audio recordings, databases and programming code).

2. It is prohibited to download any part of the site, images, fragments or texts in whole for commercial, educational or any other purposes, except for personal use. To use information from the Platform for other purposes, prior consent of the Platform Owner is required.

3. Unauthorised use of any part of the Platform without the consent of the copyright holder (Platform Owner, collaborators, users) is considered copyright infringement and is subject to legal action.

4. If you become aware of any such violation, please report it to us immediately so that we can respond appropriately. The Platform Owner is not liable for any possible copyright infringement but will take appropriate action if such a violation is established.

12. Terms of use of content

1. We provide users with Platform content in good faith. All visitors are entitled to use the Platform's content as long as they do not violate the terms of use.

2. The Platform consists of various content (own content, content of collaborators, partners and advertisers, free content, paid content, comments by visitors and links to external pages). You use all Platform content at your own risk, and the Platform Owner cannot be held liable for any damage arising from such use.

13. Final provisions

These Terms of Use and Privacy Policy are drafted in accordance with the laws of the Republic of Serbia, the mandates of the National Bank of Serbia and the Operating Rules of Monri Payments, as the authorised processor of card payments.

Any disputes arising from the use of the Platform shall fall within the jurisdiction of the competent court in Belgrade, Republic of Serbia.

BalancePath d.o.o. reserves the right to update this document from time to time. The current version is always available at https://balancepath.space/terms-of-use.