Contract manufacturing and brand access terms. One product file, four parties, clear roles.

1.1. These terms are between the company or person using the platform in one of the roles below and Wennes Biyoteknoloji Limited Şirketi (Unique Alphabet®, "we"). For the file owner, the Terms of use and their annex, the Data Processing Agreement, also apply; these terms do not change them but add rules specific to contract manufacturing.

1.2. Roles:

• File owner: the Customer that opens the product file in its own account — usually the consultant, sometimes the brand or the manufacturer itself. It pays for the file (§07) and decides whom to invite.
• Consultant: the company that prepares the file for the brand, collects documents and builds the file. It owns the files it opens in its own account.
• Manufacturer: the company that manufactures the product for the brand. It provides the formula and the supplier list, and chooses per product whether the formula percentages are shown to the brand (§05). It does not need an account; it comes through a MakerLink or Maker Portal.
• Brand: the company that places the product on the market under its own name or trademark. It signs in to Maker Portal free of charge and sees its own products' files. Within the meaning of EU Regulation 1223/2009, it is usually the "manufacturer" (Article 2(1)(d)) and the responsible person (Article 4).
• Responsible Person: if the brand has designated someone else in writing (e.g. a responsible person in Türkiye or the EU), that person appears in the file in this role. If the role is empty, the Responsible Person's powers under these terms belong to the brand.
• Assessor: the qualified person who reviews the file and signs the safety assessment. The file owner invites them.

1.3. A company can hold more than one role (e.g. manufacturer, and file owner for its own brand). Each product file shows which company holds which role and who makes the notification (EU CPNP, Türkiye ÜTS).

1.4. A MakerLink is the link a file owner sends a manufacturer to ask for the formula and supplier list; Maker Portal is the portal the manufacturer signs in to with its email address to see its linked products (portal.uniquealphabet.com).

1.5. Providing documents as a supplier is governed not by these terms but by the Supplier terms of use. The platform is offered to businesses; you accept these terms for your commercial or professional activity.

2.1. A link between a product and its manufacturer is created only with both parties' confirmation; the platform does not create it on its own, and a manufacturer cannot search the database for someone else's product.

• If the file owner starts it: it enters the manufacturer's email in the "Manufacturer" field of the product's identity details, or sends the manufacturer a MakerLink; the manufacturer receives an email saying "Company X added product Y as manufactured by you"; if the manufacturer confirms, the product appears in its Brands view.
• If the manufacturer starts it: it enters the consultant's email and the product names in Maker Portal; a request goes to the consultant, who matches them to its products and confirms. Unmatched lines are shown to the consultant; no product is created automatically.

2.2. A manufacturer that confirms represents that it manufactures or will manufacture the product; a file owner that confirms represents that it is entitled to link the manufacturer to the product. The party making an untrue representation is liable for it.

2.3. Until the link is confirmed, the manufacturer sees only the information in the email (the file owner's name and the product name). If the product name is still confidential (e.g. before launch), the file owner considers this before starting the link; the platform reminds it before it does.

2.4. Either party can end the link at any time. Once it ends, the manufacturer no longer sees that product's file; the file stays with the file owner. Even after the link ends, the confidentiality the manufacturer chose and the sealed composition of versions placed on the market are protected under §5.6.

2.5. If you name the consultant. If the email address you enter under "Connect to my consultant" is not registered on the platform, a fixed-text email notifying your request is sent to that address once, on your behalf; if the email cannot be sent, or the recipient has previously declined such notices, you are shown a link and a short ready-made text to pass on to that person yourself. By entering the address you represent that: you obtained it within your business relationship with that person; its owner really is the person or company preparing the files for the products you list; and you are not using it for bulk or promotional purposes. No further notice goes to the same address, and we do not tell you the outcome. If the recipient declines, the address is not used in any manufacturer's request again. If this representation is untrue, you are liable for the resulting damage and we may close your Maker Portal access.

4.1. Who owns the formula and the file content depends on the contract between the manufacturer and the brand (and the consultant); the platform does not decide this. These terms only govern who sees what on the platform.

4.2. If the brand claims it owns the formula under contract or is entitled to the percentages, and the manufacturer nonetheless keeps them hidden, that dispute is between the parties. The platform applies the manufacturer's choice; authority access (§06) works in every case; we comply with any court or competent authority order.

4.3. A formula sent through a MakerLink arrives in the file owner's product as a suggestion; it is not written into the formula until the file owner approves it. Supplier names and emails provided by the manufacturer pass to the file owner's supplier list as suggestions, and the file owner can request documents from those suppliers; the manufacturer represents that it is entitled to provide this information.

4.4. We use the formula and the file only to run the platform for these parties; we do not use them to train AI models.

4.5. My formulas and automatic sending. We keep every formula the manufacturer sends through a MakerLink, encrypted, in the manufacturer's library in Maker Portal (My formulas), so it can be reused for later requests; the manufacturer can also add formulas to the library itself. The library is visible only to the manufacturer; the file owner, the brand and the other parties do not see it. The manufacturer can turn on "auto-send" for a formula (off by default): while it is on, when the same file owner asks again for the formula of the same product, we send the version last sent for that product without waiting for the manufacturer's separate approval; we do not send it if the product–manufacturer link is not confirmed or the manufacturer's account is suspended. The manufacturer can send a new version of a formula to the products using it that it chooses. A formula sent automatically or by choice is, as in §4.3, a suggestion; it is not written into the formula until the file owner approves it. We notify the manufacturer of every automatic send by email and in the portal; the setting can be turned off at any time. The last sentence of §9.1 applies to supplier contacts stored with a formula in My formulas. The manufacturer can ask for a formula to be deleted from the library by writing to dev@uniquealphabet.com; suggestions already sent to a file owner and approved formulas are not affected.

4.6. Sharing a formula (outside Alphabet). 4.6.1. What: the manufacturer can send a version of a formula in My formulas, from Maker Portal, to its own customers and business contacts who do not use Unique Alphabet®: an access email goes to the recipient's address, or the manufacturer forwards a link it copies with its own email. The recipient views the formula on the page behind the link and can download it as a table. 4.6.2. What is sent: the content of the version current at the time of sharing; a version saved later does not reach the recipient. By default only the INCI names are sent; percentages are sent only if the manufacturer chooses so separately for each share. Supplier names and contact details stored with the formula are never sent, whatever the choice. 4.6.3. Whose decision: sharing a formula is the manufacturer's own decision and responsibility. The percentage confidentiality in §05 governs visibility within the file owner's file; it does not restrict the manufacturer from sharing its own formula and gives no right to the file owner, the brand or the Responsible Person. Where the formula does not belong to the manufacturer, or sharing it is prohibited by a contract (confidentiality, exclusivity), it is the manufacturer's obligation not to share it; §4.1–4.2 apply here too. 4.6.4. Sender identity: the email is sent from raw.uniquealphabet.com, separate from the platform's emails, with the sender name "Your company via Maker Portal" and the manufacturer's email as the reply-to address. The template is fixed; the formula's content is not included in the email, only its name, version, number of ingredients and whether percentages are included. The note the manufacturer may add is at most 300 characters and cannot contain links. 4.6.5. Limits: the number of recipients per day is limited, and lower in the first days after the manufacturer first accepts these terms; sends from the same email address through Raw Portal sharing count together. The same content goes to the same recipient at most once a week. The link is valid for 7, 14 or 30 days; the manufacturer can cancel it at any time in My formulas and sees how many times each link was opened. Once cancelled or expired the page no longer opens; a table the recipient has already downloaded stays with them. 4.6.6. The manufacturer's responsibility: it sends only to recipients with whom it has a business relationship and who have a legitimate reason to receive the formula; it represents that it obtained the recipients' addresses lawfully and is entitled to send them this message; it does not use sharing as a promotional or bulk email tool. The accuracy of the shared formula, how the recipient uses it and the relationship with the recipient are the manufacturer's responsibility; requests and complaints from recipients are directed to it. 4.6.7. Blocking and abuse: Supplier Terms of Use §10A.6–10A.7 apply as they stand ("Maker Portal" instead of "Raw Portal"): every email has a one-click "block this sender" option and the manufacturer cannot lift the block; the recipient page has "Report abuse"; sending stops automatically if a threshold is exceeded and, in serious or repeated cases, we may close sharing or Maker Portal access. Blocking and closing are shared by both portals: a recipient's block applies to all shares from that manufacturer's email address. 4.6.8. No support: we do not provide support to recipients; the email and the recipient page say "reply to the sender with any questions". We are only the technical intermediary; we do not check the formula's content. 4.6.9. Recipients' data: recipient addresses and delivery results are processed on the manufacturer's behalf (§9.4); we do not use them for promotion or any other purpose. The number of times the recipient page was opened and the time it was last opened are kept to show the manufacturer and to monitor abuse. 4.6.10. Sharing a formula is free of charge and subject to the liability limits in §11; "the formula reaching an unauthorised person" in §11.2 does not cover a recipient the manufacturer chose itself — a formula reaching that recipient does so by the manufacturer's decision. We may change or discontinue the function with prior notice.

5.1. The manufacturer chooses, for each product, whether the percentages are "Hidden" or "Visible" to the brand; if no choice is made, the default is Hidden. The choice is per product, can be changed, and every change is logged.

5.2. When "Hidden" is chosen, the percentages are hidden from the brand, the Responsible Person and share recipients. The file owner and the invited assessor continue to see them; the file and the safety assessment cannot be built without them (Regulation 1223/2009 Article 10, Annex I Part A §1). The file owner agrees not to pass hidden percentages to the brand by other means; the platform removes the percentages for the brand and share recipients when a hidden product is exported or shared. If the file owner is the brand itself, the percentages are visible to it and confidentiality does not operate against that brand; the platform tells the manufacturer so before it sends the formula.

5.3. In a "Hidden" product the brand sees: the INCI list (in descending order as on the label, without percentages), compliance status and check results, and the signed safety report — with the quantitative values in the composition section shown as "sealed".

5.4. A manufacturer choosing "Hidden" expressly accepts in advance that the percentages may be opened, without its further permission, only in an authority request under §06. This acceptance exists so that the responsible person's duty to keep the product information file readily accessible to the competent authority (Regulation 1223/2009 Article 11(3)) does not depend on the manufacturer's cooperation on the day.

5.5. The frame formulation needed for notification (Regulation 1223/2009 Article 13(1)(h)) can be produced in ranges without showing exact percentages; the file records which role makes the notification.

5.6. Sealed composition: the composition of every product version marked in the file as placed on the market is kept sealed for ten years after the last batch is placed on the market (Regulation 1223/2009 Article 11(1)), even if the link ends or the manufacturer leaves the platform. The manufacturer cannot delete these versions; it only chooses the visibility of new versions. Storage counts towards the file owner's storage.

6.1. The party in the Responsible Person role (the brand, if the role is empty) can open an authority request on the platform for a competent authority's request for the product information file: it enters the authority's name and the date and reference of the request, and uploads the request letter.

6.2. Once the request is opened, the platform exports the full product information file including percentages, without waiting for our approval; the export carries a stamp "only for this request of this authority". The opening is logged and notified to the manufacturer immediately; the manufacturer's permission is not awaited (§5.4).

6.3. Opening a request without a real authority request is a material breach of these terms: we may suspend and terminate the account, and the party opening it is liable to the manufacturer for the resulting damage. We share request records at the request of the manufacturer and the authority concerned.

6.4. If a court or competent authority applies to us directly, we comply with a lawful request and, unless the law prevents it, notify the file owner, the Responsible Person and the manufacturer.

6.5. We do not open accounts on the platform for competent authorities directly.

7.1. The file owner pays. The price is tied to the file, not to the person: whoever works on the file, the Customer that opened it in its own account pays under the plan and new file allowance rules in the Terms of use.

7.2. The manufacturer, the brand and the assessor do not pay because they work in someone else's file. A brand account is a free viewer account; if a brand opens a file for its own product it becomes that file's owner and pays. The same rule applies if a manufacturer opens a file in its own account; if its number of company profiles exceeds its plan's limit, we proceed with an Enterprise offer.

7.3. An invited assessor counts as a seat. When a file owner invites an assessor, the assessor uses one user seat of the inviting account; the assessor does not pay. The assessor's powers are limited to review, comment and signature; a person who needs editing rights is added as a normal team member (also a seat).

8.1. The file owner chooses and invites the assessor. The platform does not suggest, appoint or verify assessors; checking that the assessor has the qualifications required by Regulation 1223/2009 Article 10(2) and Turkish law is the task of the inviting party and the responsible person.

8.2. The safety assessment and signature are the assessor's; the platform does not carry out or replace that assessment (Terms of use §02, §14).

8.3. The assessor uses the formula and information learned in the file only to assess that file and keeps them confidential; this obligation continues after the invitation ends.

9.1. The file owner is the controller of the personal data in the product file (names and contact details of the assessor, the Responsible Person, the manufacturer's and brand's staff, and the supplier contacts the manufacturer provides); we process it on its behalf under the Data Processing Agreement. The file owner informs the parties joining the file under its own duty to inform; the manufacturer is responsible for telling the supplier contacts it provides that they will be used for this purpose.

9.2. We are the controller of the platform account data of the manufacturer, the brand and the assessor (sign-in email, session records, IP, acceptance record); the Privacy notice applies.

9.3. The product–manufacturer link and the percentage visibility choice are applied on the file owner's instructions together with these terms; by accepting these terms, the file owner instructs us to apply the manufacturer's visibility choice in its file.

9.4. For the manufacturer's formula sharing (§4.6), the manufacturer is the controller of recipient addresses and delivery results and we process them on its behalf; we are the controller of the recipient's block record and abuse reports (KVKK Article 5(2)(f); to carry out the recipient's wish and prevent abuse). The processor provisions in Supplier Terms of Use §09 apply to this processing too.

10.1. The manufacturer and the brand sign in to Maker Portal with a single-use email link, without a password; the rules in Supplier terms of use §02 apply equally.

10.2. A MakerLink is valid for 30 days and opens with a password. The password may be sent in the same email as the link or through a separate channel, as the file owner chooses. If it travels in the same email, anyone with access to that email can open the formula page; the security of the inbox is the recipient's responsibility, and how the password is sent is the file owner's.

10.3. MakerLinks, link requests, confirmations, confidentiality changes, authority request notices, reminders and signature requests are transactional messages and contain no promotion.

11.1. Our liability to the file owner is subject to Terms of use §14.

11.2. Towards the manufacturer, brand, Responsible Person and assessor using the platform free of charge, except for our intent or gross negligence, damage to life or health, and other liability that the law does not allow to be limited, our total liability of every kind — whether for breach of contract, tort or any other legal ground, including a formula reaching an unauthorised person — is limited to 5,000 TL for a party established in Türkiye and €150 for a party established outside Türkiye, and covers only direct loss. With the same exceptions we are not liable for indirect loss; the acts of our providers are subject to the same limits. These limits reflect that the service is provided to these parties free of charge.

11.3. The platform does not decide on product safety, compliance or placing on the market; those decisions and their consequences belong to the responsible person, the assessor and the brand.

12.1. As regards changes, governing law, jurisdiction, language and notices, Supplier terms of use §15–§17 apply equally to these terms, reading the relevant role for "Supplier" and "Maker Portal" for "Raw Portal". For the file owner, Terms of use §15–§18 apply.

12.2. There is no support service for manufacturers, brands and assessors; questions about a file go to its owner. For account security, abuse and personal data requests: dev@uniquealphabet.com and hello@uniquealphabet.com.