Data Use Terms
EULA Annex B · Version 1.0 · Last updated: March 6, 2026
DRAFT. This schedule requires Finnish attorney review before execution. Contact WhatsApp for the current executable version.These Data Use Terms govern access to EU institutional data provided through Pauhu® services (cloud service and Pauhu® Connector). The underlying data originates from EU institutions and is made available under their respective licenses. Pauhu’s proprietary annotations are governed separately under the EULA.
1. Source Data Licenses
Each data source has its own license from the originating institution. The table below summarises the license, attribution requirements, and any special conditions.
| Source | License | Attribution | Conditions |
|---|---|---|---|
| EUR-Lex | CC-BY 4.0 (Commission Decision 2011/833/EU) | Required | - |
| TED (Tenders Electronic Daily) | CC-BY 4.0 | Required | Contact person data subject to GDPR |
| EU Terminology/td> | CC-BY 4.0 | Required | - |
| Eurostat | CC-BY 4.0 | Required | - |
| CURIA (Court of Justice) | CC-BY 4.0 | Required | - |
| CORDIS (Research) | CC-BY 4.0 | Required | - |
| European Parliament | CC-BY 4.0 | Required | - |
| European Commission | CC-BY 4.0 | Required | - |
| Council of the EU | CC-BY 4.0 | Required | - |
| Data Europa (Open Data Portal) | CC-BY 4.0 | Required | - |
| Publications Office | CC-BY 4.0 | Required | - |
| OEIL (Legislative Observatory) | CC-BY 4.0 | Required | - |
| ECB (European Central Bank) | Free reuse, attribution required | Required | Data shall not be modified. Presented as-is with ECB attribution. |
| ECHA (Chemicals Agency) | Free reuse (regulatory data) | Required | - |
| EMA (Medicines Agency) | Free reuse (public medicines register) | Required | - |
| EPO (Patent Office) | EPO Data Use Agreement (separate) | Per DUA | Requires signed EPO DUA. Not available until DUA is executed. |
| Who is Who (EU Officials) | CC-BY 4.0 | Required | Contains personal data (GDPR applies). Art. 17 erasure requests honoured. |
| Wikidata | CC0 1.0 (data) / CC-BY-SA 4.0 (text) | Required for CC-BY-SA | Internal use only for CC-BY-SA content. |
| DPP (Digital Product Passport) | Per-passport terms | Per issuer | Regulation (EU) 2024/1781. Terms set by passport issuer, not Pauhu. |
2. Attribution Requirements
Under CC-BY 4.0 (the predominant license), you must:
- Credit the source institution (e.g., “© European Union, 2026”)
- Provide a link to the license (https://creativecommons.org/licenses/by/4.0/)
- Indicate if changes were made (Pauhu annotations constitute changes)
Cited answers carry their source. If you redistribute data obtained through Pauhu, you must preserve this attribution.
3. Pauhu Enrichment Layer
Pauhu enriches EU source data with proprietary annotations:
- Legal modality classification: obligations, prohibitions, permissions, exemptions
- Topic classification: 21 domain categories
- Policy stance: directional assessment per document
- Confidence scores: certainty indicators per annotation
- Provenance metadata: source, timestamp, version, processing chain
The annotation methodology, schemas, and training data are Pauhu trade secrets. You may use annotation outputs in your work. You may not:
- Redistribute annotation schemas or methodology
- Use annotations to train a competing classification system
- Strip annotations from source data and resell them separately
Database rights. The Pauhu database is protected by the sui generis database right under Directive 96/9/EC, Article 7, on the basis of Pauhu Ltd’s substantial investment in obtaining, verifying and presenting its contents, and by copyright in its original selection and arrangement under Article 3 of the same Directive. These rights are independent of any rights in the underlying source contents, which remain with their publishers. The term of protection runs for fifteen years and is renewed by each substantial update to the database (Article 10(3)); the Pauhu database is updated continuously. Extraction or re-utilisation of the whole or a substantial part of the database without a licence is prohibited, as is the repeated and systematic extraction of insubstantial parts.
4. Personal Data
Two data sources contain personal data as defined under GDPR Art. 4(1):
- TED: contact person names and email addresses in procurement notices
- Who is Who: EU official names, roles, and organisational affiliations
Processing of personal data is governed by the Joint Controllership Agreement (EULA Annex A). Key rights:
- Art. 17 Erasure: data subjects may request deletion via WhatsApp
- Art. 22: no automated individual decisions are made solely on the basis of Pauhu outputs
- Art. 15 Access: data subjects may request access to their data held in Pauhu systems
5. Permitted Use
You may use data obtained through Pauhu for:
- Internal research, analysis, and decision support
- Policy drafting and legislative analysis
- Procurement document preparation
- Compliance monitoring and regulatory intelligence
- Translation and multilingual access to EU legislation
6. Prohibited Use
You may NOT:
- Resell or redistribute raw EU source data as a competing data service
- Remove or alter source attribution
- Present Pauhu-generated annotations as official EU institutional positions
- Use outputs as the sole basis for automated legal decisions affecting individuals (GDPR Art. 22)
- Modify ECB statistical data (ECB reuse terms)
- Use EPO data without a signed Data Use Agreement
7. Data Freshness
Pauhu maintains data freshness through automated sync from EU institutional sources. Update frequency varies by source (from daily to weekly). For sovereign deployments, update frequency depends on your subscription tier and update schedule configuration.
Pauhu does not guarantee that data is current at any given moment. For authoritative and legally binding text, always refer to the official source (EUR-Lex, Official Journal, etc.).
8. Text and Data Mining
Pauhu’s processing of EU institutional data is conducted under EU DSM Directive 2019/790, Art. 4 (text and data mining for any purpose). We respect machine-readable TDM opt-out signals and exclude sources that reserve TDM rights.
If you use Pauhu data for your own TDM activities, you are responsible for compliance with Art. 3 or Art. 4 of the DSM Directive as applicable to your use case.
Reservation of rights. Pauhu Ltd expressly reserves the use of the Pauhu database and its contents for text and data mining, in machine readable form, in accordance with Article 4(3) of Directive (EU) 2019/790. The general text and data mining exception of Article 4 therefore does not apply to the Pauhu database. Text and data mining of the Pauhu database, including for the development or training of AI systems, requires a separate licence agreed through the Pauhu Connector. The mandatory exception for scientific research under Article 3 remains unaffected.
9. Governing Law
These Data Use Terms are governed by Finnish law. Disputes shall be resolved in the Helsinki District Court (Helsingin käräjäoikeus).
10. Contact
Questions about data licensing: WhatsApp
Data protection and erasure requests: WhatsApp
Pauhu Ltd (Y-tunnus: 0768171-8) · Helsinki, Finland · EU jurisdiction