Annex C – Attribution Policy and Fee Allocation

1. Purpose

1.1. This Annex explains how Nuento determines who has generated a Customer and a specific order – the Supplier (via its own channels) or Nuento (via its marketplace and marketing) – and therefore which fee level applies to that order.

1.2. The purpose is to ensure a fair and transparent allocation between:

• Supplier-generated traffic (own marketing and direct channels), and
• Platform-generated traffic (Nuento’s marketing and marketplace).

2. Definitions

Attribution

The method by which Nuento determines whether an order was generated via the Supplier’s own channels or via Nuento’s marketing and marketplace.

Attribution Window

A period of 90 days from the Customer’s first recorded interaction with the Nuento platform (website or app) in relation to a Supplier or an order.

Interaction

Any action where the Customer, via Nuento’s website or app:

• searches for Suppliers or products,
• starts or completes an order, or
• clicks on a link from Nuento’s marketing (for example Google Ads, Meta, e-mails or other campaigns).

Supplier Referral

When a Customer visits Nuento via a link, QR code or embedded booking solution generated for the Supplier and distributed through the Supplier’s own channels (e.g. website, e-mail, social media, printed materials).

3. Attribution principles

3.1. First interaction determines ownership

3.1.1. If the Customer’s first recorded interaction within the Attribution Window comes from Nuento’s own marketing or marketplace (including organic visits to the Nuento site or app), the order is attributed to Nuento, even if the Customer later returns via the Supplier’s own links.

3.1.2. If the Customer’s first recorded interaction within the Attribution Window comes from a Supplier Referral (Supplier’s own link, QR or embed) and there is no prior interaction via Nuento’s marketing, the order is attributed to the Supplier.

• In that case, only the 2% payment fee applies, see the Supplier Terms.

3.1.3. Mere exposure to Nuento advertising without a measurable interaction (for example, seeing an ad but not clicking it) does not count as a first interaction.

3.2. Subsequent interactions

3.2.1. If the Customer first interacts via Nuento’s marketing or marketplace and later returns via a Supplier Referral within 90 days, the order is still attributed to Nuento. Nuento retains attribution for the length of the Attribution Window, unless the window expires without any further interaction.

3.2.2. If the Customer first visits Nuento via a Supplier Referral, and later returns via Nuento marketing within the same 90-day window, the order remains attributed to the Supplier, provided the first recorded interaction was via the Supplier’s channel.

3.2.3. If no reliable source can be established (for example, due to technical limitations, cookie blockages or missing tracking parameters), the order is by default attributed to the Supplier, and only the 2% payment fee applies.

4. Technical guidelines

4.1. Nuento records visits using cookies, URL parameters and referrer data where available and lawful.

4.2. The system stores source information for each user within the 90-day Attribution Window to determine whether the first interaction came from Nuento or the Supplier.

4.3. If no reliable source can be established with reasonable certainty, the order is attributed to the Supplier.

4.4. The Supplier may contact Nuento to obtain an explanation of how the attribution for a specific order has been recorded. Nuento will provide reasonable information but is not required to disclose confidential details of its tracking systems.

4.5. Attribution is determined solely for the purpose of fee allocation between Nuento and the Supplier and does not affect any rights or obligations between Supplier and Customer.

5. Changes and adjustments

5.1. Nuento may adjust the length of the Attribution Window, the technical methods used or the attribution logic where reasonably necessary to:

• reflect market practice,
• ensure accurate measurement, or
• comply with legal requirements (including data protection and cookie rules).

5.2. Any material changes will be notified to the Supplier with at least 30 days’ notice and will apply only to orders placed after the change takes effect.

6. Force majeure and misuse

6.1. In case of suspected misuse of Supplier links, for example through automated traffic, artificial self-referrals or other manipulation, Nuento is entitled to override the standard attribution result.

6.2. In such cases, Nuento may attribute affected orders to Nuento and charge the full platform fee, or take other appropriate measures (including suspension), where justified.

6.3. Nuento will act reasonably and may request documentation or explanation from the Supplier before changing attribution in suspected misuse cases.

This Annex forms an integral part of the Supplier Terms.