Honolulu Star Bulletin - ADVERTISEMENT

ADVERTISING AND TERMS OF ADVERTISING SERVICES OF "HONOLULU STAR-BULLETIN"

0. Advertising: general information
"HONOLULU STAR-BULLETIN" offers advertising opportunities within its digital publication, subject to availability, the agreed campaign specifications and these terms. Services may include display advertising, clearly identified advertising features, sponsored content, video, contextual placements and other expressly agreed formats. Each proposal must identify the services offered, publication channels, campaign period, price and applicable measurement arrangements. Audience estimates and illustrative forecasts must be distinguished from contractual commitments. Advertising expenditure does not purchase editorial influence, favorable independent reporting, endorsement by the publication or the suppression of legitimate journalism. The advertising supplier and the client’s contracting party is SCANDIC TRUST GROUP LLC, a limited liability company incorporated under Ukrainian law, registration number 1010351020000018952. SCANDIC ASSETS FZCO provides technical operation and administration within the scope of its appointment. LEGIER Beteiligungs mbH acts as an authorized payment recipient and advertising contact as described in section 8.1. Technical assistance, campaign administration or receipt of payment does not, by itself, transfer the supplier’s contractual obligations to either company.

Advertising enquiries
Publication contact: [email protected]

0.1. Legal requirements for advertising
Advertising must comply with the laws applicable to its content, audience, distribution and commercial purpose. Campaigns directed at Honolulu, the State of Hawaii or the wider United States market must satisfy applicable federal and state requirements. Distribution into another jurisdiction may create additional obligations. The client must identify the advertiser, the products or services promoted, the intended audience and any material regulatory restrictions, and must supply the evidence reasonably required to assess compliance. The supplier remains responsible for its own conduct and for obligations imposed directly upon it. Acceptance of an advertisement does not constitute governmental approval, regulatory clearance or a guarantee that every legal requirement has been satisfied.

Identification of advertising and editorial independence
Advertising must be recognizable as advertising. Sponsored articles, native advertising, advertising features, affiliate promotions and paid endorsements must carry a clear and prominent disclosure appropriate to their format and context, such as "Advertisement", "Paid Advertisement" or "Sponsored Advertising Content". Where identification is necessary to prevent deception, it must appear before readers engage with the promotional material and remain clear on the destination page. Commercial content must not falsely appear to be independent reporting, an impartial recommendation or an unsolicited personal opinion. Disclosures must remain effective on mobile devices, in previews and in other agreed distribution formats. Material sponsorship, commissions, gifts, employment relationships and other connections must be disclosed where they could affect the audience’s assessment of an endorsement. Independent editorial decisions remain with the publication.

Accuracy, substantiation, testimonials and reviews
Advertising must not mislead through statements, imagery, omissions, qualifications or its overall impression. Objective claims must have an adequate evidential basis before publication. Health, safety, performance and earnings claims require substantiation appropriate to the claim and the applicable legal standard. Qualifications must be clear, timely and sufficiently prominent; they must not contradict the principal message. Testimonials must reflect genuine experience, and exceptional results must not be presented as generally expected without adequate support and disclosure. Fabricated reviews, fictitious customer experiences, misleading insider testimonials and falsely independent review websites are prohibited. Incentives must not be conditioned, expressly or implicitly, on a particular positive or negative review sentiment where prohibited by law. Material incentives must be disclosed even where the incentive itself is permissible. Review suppression, selective presentation and purchased indicators of social influence must not create a deceptive impression. Approval by the advertiser does not make an unlawful claim acceptable.

Prices, comparisons and promotional offers
Advertisements must disclose material pricing conditions, unavoidable charges and significant restrictions clearly and at the appropriate stage. Discounts, reference prices, savings, limited availability and closing dates must be accurate and supported by evidence. Optional extras must remain genuinely optional. Advertisements for live-event tickets and short-term lodging must comply, where applicable, with the Federal Trade Commission’s Rule on Unfair or Deceptive Fees and Hawaii’s corresponding requirements under Act 254, Session Laws of Hawaii 2026. Covered offers must prominently disclose the required total price; exclusions for government charges, shipping or genuinely optional items are permitted only within the applicable rules, with the required information provided before payment. Those sector-specific requirements must not be represented as a universal federal pricing rule for every product. Comparisons with competitors must be truthful and must not misrepresent comparable features, prices, sponsorship or affiliation. Sweepstakes, competitions and promotional offers must disclose material eligibility requirements, entry conditions, closing dates and restrictions and must not constitute unlawful gambling.

Dignity, discrimination and responsible presentation
Advertising must comply with applicable civil rights, privacy and anti-discrimination laws. Employment and housing advertisements, including their audience selection and delivery, must not unlawfully exclude protected groups or communicate unlawful preferences. Relevant requirements include Title VII of the Civil Rights Act of 1964, the Fair Housing Act and Hawaii Revised Statutes Chapters 378 and 515, according to their respective scope. Covered job listings must disclose the hourly rate or salary range required by Hawaii Revised Statutes section 378-2.8, subject to its statutory exceptions. The supplier may decline material that promotes harassment, threats, unlawful violence or the exploitation of vulnerable people. Contractual content standards may be more restrictive than the minimum required by law, but their application must remain lawful.

Environmental and sustainability claims
Environmental claims must be specific, substantiated and proportionate to the benefit established. Broad claims such as "green", "environmentally friendly", "sustainable", "carbon neutral" or "net zero" must not convey benefits that the evidence cannot support. Material limitations, the basis of comparisons, relevant lifecycle effects and reliance on offsets must be explained where necessary to prevent deception. Claims concerning recyclability, recycled content, renewable materials, renewable energy or environmental certifications must accurately reflect the relevant conditions and scope. An improvement to one component must not misleadingly describe the entire product or business. The Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims inform the assessment of deceptive environmental advertising; they are interpretive guidance and do not constitute a blanket certification or safe harbor.

Political advertising and campaign transparency
Political advertising requires prior identification of the advertiser, the person or organization paying for the communication, any person on whose behalf it is placed, the intended audience and the relevant election or political activity. Hawaii Revised Statutes section 11-391 requires applicable advertisements to identify their payer and address and to carry the required approval or non-approval information, subject to statutory exceptions. Federal election advertising must satisfy applicable requirements under 52 United States Code section 30120 and 11 Code of Federal Regulations section 110.11. Campaign reporting, electioneering communication and recordkeeping requirements must also be observed where applicable. False information about voting procedures, dates, locations or eligibility must not be published. Hawaii Revised Statutes sections 11-303 and 11-304 address materially deceptive election advertising and related remedies. During the statutory election period, covered manipulated media must not be distributed in violation of those provisions. Any reliance on the statutory disclosure exception requires the prescribed presentation, language and, where applicable, identification of the original source material; a generic "AI-generated" label is not necessarily sufficient. Political advertisements also require assessment under applicable restrictions on foreign-national financing and participation in election-related decision-making. Ordinary commercial advertising services must not be converted into prohibited contributions, subsidized campaign support or unlawful strategic participation. Placement in this publication does not establish that a campaign’s funding, expenditure or reporting arrangements are lawful.

Children and young people
Campaign design, placement and targeting must take account of children’s age, understanding and vulnerability. Under these terms, advertising must not exploit children’s inexperience, falsely suggest parental or school approval, or disguise a commercial message as an essential instruction or personal communication. Age-restricted products require appropriate placement and audience controls. Where the Children’s Online Privacy Protection Act and 16 Code of Federal Regulations Part 312 apply, personal information concerning children under thirteen must be handled in accordance with their notice, parental consent, security and retention requirements. The amended rule’s separate parental consent requirements for covered third-party disclosures, including disclosures for targeted advertising, must be observed where applicable. An advertiser’s statement that a campaign is intended for adults does not override its actual content, audience or collection practices.

Food, alcohol, tobacco, vaping and nicotine products
Food, beverage and dietary supplement advertising must comply with applicable Federal Trade Commission and Food and Drug Administration requirements. Nutrition, health and disease-related claims must have the necessary legal and evidential basis. A dietary supplement must not be presented as approved by the Food and Drug Administration merely because it is marketed as a supplement, and a disclaimer cannot cure an otherwise deceptive claim. Alcohol advertising must comply with applicable federal requirements, Hawaii liquor laws and licensing restrictions and must not target people below the lawful drinking age. Tobacco, vaping and nicotine advertising requires compliance with product authorization, marketing, warning, age and distribution restrictions applicable to the particular product and communication. Lawful access to one market does not establish authorization to market the same product elsewhere. The supplier may require documentary evidence of relevant licenses or product authorizations before accepting a campaign.

Gambling, medicines and financial promotions
Advertising must not promote gambling activities that are unlawful for the intended Hawaii audience. A license issued by another state or country does not, by itself, authorize gambling operations or solicitation in Hawaii. Promotions involving prizes, entry payments or chance require assessment under applicable gambling and promotional laws. Advertising for medicines, medical devices and health services must satisfy the requirements applicable to the product, advertiser and format. Direct-to-consumer advertising of prescription medicines is not categorically prohibited in the United States, but covered advertisements must comply with applicable requirements concerning truthful presentation, material facts, risk information and fair balance. Health claims must not exceed the evidence or the lawful scope of the product’s authorization. Financial, investment, credit and insurance advertisements must comply with the applicable federal and Hawaii regulatory regimes, including licensing, disclosure and anti-fraud requirements. Advertisements must not guarantee investment returns or conceal material risks, costs or conflicts. Where section 17(b) of the Securities Act of 1933 applies to a paid securities promotion, the required disclosure of consideration must be made; a general advertising label alone is insufficient. Digital assets require assessment according to their actual legal classification and the activity promoted. Publication does not constitute investment advice, regulatory authorization or a representation that the advertiser is licensed.

Personal information, advertising technology and targeting
Advertising technology must be deployed consistently with applicable privacy laws, the publication’s Privacy Policy, the information given to users and any consent or opt-out requirements governing the activity. Relevant Hawaii provisions include Hawaii Revised Statutes Chapters 487J, 487N and 487R. Federal requirements may include the Children’s Online Privacy Protection Act, the Video Privacy Protection Act and laws governing the interception or disclosure of communications, according to their scope. Customer lists, audience matching, location information, retargeting and inferred characteristics must not be used without the necessary rights and legal basis. Sensitive information must not be inferred, disclosed or used unlawfully. United States law does not impose one uniform consent rule on every advertising cookie or tracking technology. Requirements depend on the technology, information, users and jurisdictions involved. Where consent is required, the relevant activity must not begin before valid consent, and withdrawal must be respected. Applicable opt-out rights and legally recognized preference signals must be honored. Hashing, pseudonymization or replacing a name with an identifier does not automatically make information anonymous. Neither these terms nor an advertiser’s contract substitutes for a user’s required permission.

Electronic direct marketing
Commercial email must comply with the CAN-SPAM Act, including applicable requirements concerning accurate sender information and subject lines, advertising identification, a valid physical postal address and a clear opt-out mechanism. Applicable opt-out requests must be honored within ten business days, and recipients must not be charged or required to provide unnecessary personal information to unsubscribe. Federal commercial email law does not impose a universal prior-consent requirement, but additional laws, platform requirements or contractual commitments may do so. Business-to-business messages are not automatically exempt from CAN-SPAM. Marketing calls and text messages must comply with the Telephone Consumer Protection Act, applicable Federal Communications Commission rules, do-not-call requirements and relevant state law. Purchased contact information does not establish permission for every proposed use. The advertiser and the service provider remain responsible for duties applicable to their respective conduct.

Artificial intelligence and synthetic content
AI-assisted advertising remains subject to requirements concerning truthfulness, substantiation, intellectual property, privacy and recognizable commercial intent. Synthetic people or voices must not be presented as genuine customers, experts or endorsers where that presentation is false or misleading. An artificial spokesperson is not inherently prohibited, but its use must not fabricate personal experience, professional qualifications or an endorsement. Under these terms, artificial generation or material alteration must be disclosed where its omission would materially mislead the audience. Names, likenesses, voices and other identifying characteristics require the permissions or other lawful basis applicable to their use. Election advertising is additionally subject to the specific requirements described above. Use of an automated tool does not transfer responsibility for the resulting advertisement to the tool or its provider.

0.2. Legal framework and relevant case law
The following legislation and regulatory instruments are relevant according to their subject matter, territorial reach and applicability:

- Sections 5 and 12 of the Federal Trade Commission Act, 15 United States Code sections 45 and 52, concerning unfair or deceptive practices and specified false advertising; Hawaii Revised Statutes Chapters 480 and 481A, concerning unfair competition and deceptive trade practices.
- Section 43(a) of the Lanham Act, 15 United States Code section 1125(a), concerning false advertising and misleading representations of origin, affiliation or sponsorship within its scope.
- The Federal Trade Commission’s Rule on the Use of Consumer Reviews and Testimonials, 16 Code of Federal Regulations Part 465, and its Rule on Unfair or Deceptive Fees, 16 Code of Federal Regulations Part 464.
- Act 254, Session Laws of Hawaii 2026, adding requirements concerning advertised prices and fees for live-event tickets and short-term lodging to Hawaii Revised Statutes Chapter 481B.
- The Copyright Act, Title 17 of the United States Code, applicable federal trademark law and Hawaii Revised Statutes Chapter 482P concerning rights of publicity.
- The Electronic Signatures in Global and National Commerce Act, 15 United States Code sections 7001–7031, and Hawaii’s Uniform Electronic Transactions Act, Hawaii Revised Statutes Chapter 489E.
- Hawaii Revised Statutes Chapter 481C, the Federal Trade Commission’s Cooling-Off Rule at 16 Code of Federal Regulations Part 429, the Restore Online Shoppers’ Confidence Act and Hawaii Revised Statutes section 481-9.5, where their respective cancellation or recurring-payment provisions apply.
- Hawaii Revised Statutes Chapter 478 concerning interest, together with applicable contract law governing payment, damages, mitigation and enforceability.
- The CAN-SPAM Act, the Telephone Consumer Protection Act, the Children’s Online Privacy Protection Act, the Video Privacy Protection Act and applicable federal communications privacy laws, together with relevant Hawaii privacy and information security provisions.
- Applicable federal election law, including 52 United States Code sections 30120 and 30121, and Hawaii Revised Statutes Chapter 11 concerning political advertising, campaign disclosures and materially deceptive election media.
- Applicable civil rights, housing, employment, food, drug, tobacco, alcohol, gambling, securities, banking, credit and insurance laws, including the sector-specific provisions relevant to each campaign.

The Federal Trade Commission’s Endorsement Guides, 16 Code of Federal Regulations Part 255, and Green Guides, 16 Code of Federal Regulations Part 260, are interpretive guides. They must be distinguished from binding trade regulation rules such as Part 465. Hawaii’s 2026 ticket and lodging pricing legislation must likewise be applied within its defined scope. Reference to a law, guide or regulator does not represent an advertisement as officially approved. Relevant decisions include Courbat v. Dahana Ranch, Inc., 111 Hawaii 254, 141 P.3d 427 (2006), addressing potentially deceptive nondisclosure of a material condition before a prepaid transaction; Berman v. Freedom Financial Network, LLC, 30 F.4th 849 (9th Cir. 2022), addressing adequate notice and unambiguous assent in online contracting under the state laws considered there; and POM Wonderful LLC v. Coca-Cola Co., 573 U.S. 102 (2014), holding that the federal food and drug regulatory framework did not preclude the competitor’s Lanham Act challenge to the food and beverage labeling at issue. Their application depends on the governing law, contractual wording and facts; none establishes automatic liability or immunity for every advertisement.

1. Orders and formation of the contract
An advertising enquiry does not itself create a payment obligation. Before acceptance, the client must receive the campaign specifications, supplier identity, price and currency, applicable taxes and unavoidable charges, payment schedule, campaign duration, cancellation arrangements and these terms in a form that can be retained. The order must identify whether an agency acts as principal or as an authorized representative of a named client. A contract arises when the supplier accepts the client’s order or the client accepts a definite offer in the manner stated in that offer. An automated acknowledgement is not acceptance unless expressly identified as such. Electronic ordering must provide clear notice of the terms and an unambiguous indication of agreement. Clients must have a reasonable opportunity to correct material submission errors. Electronic signature legislation recognizes qualifying electronic records and signatures; it does not eliminate the requirements for assent, authority or lawful contractual terms. Merely visiting a webpage does not establish acceptance of an advertising order.

2. Advertising placement and publication dates
The accepted order determines the publication channel, placement, format, dimensions, audience criteria, dates, duration and any guaranteed delivery volume. A rotating placement may appear alongside other advertisers according to the agreed arrangements. Exclusivity, a fixed position, specified surrounding content or guaranteed visibility must be expressly agreed. The supplier must not substitute another publication, materially different audience, format or campaign period without agreement where the change affects the promised service. Minor technical adjustments are permitted only where they preserve the agreed substance and presentation. The client must identify time-sensitive events before acceptance, and essential dates and applicable time zones must be recorded. A later placement is not necessarily an adequate remedy where the advertisement’s commercial purpose depended on a particular date.

3. Refusal, suspension or termination of publication
Before contracting, the supplier may decline advertising on lawful grounds, including incompatibility with disclosed advertising standards or unavailable inventory. After acceptance, suspension or removal requires a contractual or legal basis, such as unlawful content, substantiated rights infringement, a material security risk, a binding regulatory requirement or a material contractual breach. Where practicable and appropriate, the supplier will explain the issue and allow a reasonable opportunity to correct it. Immediate action may be taken where necessary to prevent harm or comply with law. Measures must be proportionate to the affected material and circumstances. Suspension does not automatically entitle the supplier to retain the entire campaign price. Charges for completed work, legally recoverable losses and refunds for undelivered services must be assessed separately. The supplier’s own breach remains subject to applicable remedies.

4. Delivery of advertising materials
The client must supply complete materials, destination links, required disclosures and supporting documentation by the agreed deadline and in the agreed technical format. Materials must be free from malicious code, unauthorized tracking, deceptive controls and undisclosed redirections. The supplier must communicate relevant technical requirements before the submission deadline. Material alterations to wording, claims or visual meaning require the client’s approval, except where immediate restriction or removal is necessary under section 3. Additional design, conversion or correction work is chargeable only where its scope and price have been agreed. Approval of a proof does not excuse an error subsequently introduced by the supplier. Clients should retain their own copies. Requests for the return of physical originals should be made within ten days after the final placement; that administrative period does not extinguish ownership, statutory rights or an otherwise valid claim.

5. Defective performance and complaints
The supplier must perform the agreed services with reasonable care and deliver the promised specifications. Clients should report missing, incorrect or defective placements promptly so that effective correction remains possible. A complaint is not automatically barred because it is made after the campaign ends or the final report is issued. The supplier will investigate and provide an explanation and the remedy required by the contract and applicable law. Appropriate remedies may include correction, replacement delivery, a proportionate price reduction, a refund or legally recoverable damages, depending on the breach and circumstances. Replacement delivery must not be imposed where it would fail to address an essential missed date or materially defeat the campaign’s purpose. Where a refund is due, the supplier will issue it without undue delay and, as a contractual commitment, within fourteen calendar days after entitlement and the amount have been established, unless the law requires earlier payment. Determination of a claim must not be unreasonably delayed to postpone reimbursement.

6. Rights in materials and third-party claims
The client must hold the rights, permissions or other lawful basis necessary for the supplied text, images, recordings, trademarks, personal information and other material. The client grants the supplier a nonexclusive license limited to producing, technically adapting, delivering and reporting on the agreed campaign. Technical providers may exercise those rights only to the extent required for their appointed functions. Submission or payment does not, by itself, transfer copyright ownership. Ownership and permitted reuse of newly commissioned material must be addressed expressly; a claimed work-made-for-hire arrangement or copyright transfer must satisfy the applicable statutory requirements, including the writing requirement where section 204 of the Copyright Act applies. Fair use and other statutory exceptions remain unaffected. Commercial use of a person’s identity must comply with applicable privacy and publicity rights, including Hawaii Revised Statutes Chapter 482P and its exceptions. Responsibility for third-party claims depends on the relevant conduct, breach, causation and applicable law. These terms do not impose an unlimited indemnity for every allegation or for the supplier’s own wrongdoing. The parties must cooperate reasonably in responding to a substantiated claim. Neither party may admit liability, bind the other to a settlement or impose defense costs on the other without authority or a valid legal basis.

7. Liability and expected campaign results
The supplier is responsible for its agreed obligations and for acts and omissions legally attributable to it. Unless expressly promised, a campaign does not guarantee a particular level of sales, enquiries, profit, search ranking or return on investment. That qualification does not reduce an agreed commitment concerning placement, duration, audience criteria, valid impressions or other defined deliverables. These terms contain no general release of the supplier from its own negligence and no automatic monetary cap on every claim. Any separately proposed limitation must be clearly disclosed, validly agreed and enforceable under applicable law. Fraud, intentional misconduct and liability that cannot lawfully be excluded remain unaffected. Statutory remedies, including those available under Hawaii Revised Statutes Chapter 480 where its requirements are satisfied, are preserved. The use of external providers does not automatically release the supplier from contractual responsibility, and any statutory protection concerning third-party content applies only within its actual scope.

8. Price, advance payment and campaign cancellation
The agreed price and payment schedule must be disclosed before the contract is formed. Unless otherwise agreed, payment is due in advance by the date stated in the accepted offer and corresponding invoice. Design, production, targeting, measurement and other additional services may not be charged without a contractual basis. Cancellation or reduction of a campaign is governed by the accepted order and applicable law. Outside an applicable statutory cancellation right, any cancellation charge must be validly agreed or otherwise legally recoverable. A stipulated damages provision must satisfy applicable enforceability requirements and must not operate as an unlawful penalty. Recoverable losses must account for costs saved and reasonable mitigation. Cancellation does not automatically make every remaining charge payable. Where the supplier cancels without contractual or legal entitlement, the client retains the remedies arising from that breach. Refunds must not be replaced with advertising credit without the client’s agreement.

8.1. Authorized payment recipient
Advertising payments may be collected on the supplier’s behalf by:

LEGIER Beteiligungs mbH
Kurfürstendamm 14
10719 Berlin
Federal Republic of Germany
Commercial register: HRB 57837
Registration court: Amtsgericht Charlottenburg, Berlin
VAT identification number: DE413445833
Email: [email protected]

Payment to an account identified in a valid invoice as an authorized collection account discharges the corresponding payment obligation to SCANDIC TRUST GROUP LLC to the extent received. The invoice must accurately identify the supplier and the capacity in which payment is collected. The German collection address does not, by itself, determine the applicable tax treatment, place of supply or governing law. Responsibility for the advertising service and refunds owed by the supplier remains with the supplier. Changes to payment instructions must be communicated through an authenticated channel. Clients may verify changed instructions using the established contact details before transferring funds.

9. Late payment
If an undisputed amount is overdue, the supplier may issue a payment reminder and, after appropriate notice, suspend the affected service to the extent reasonably justified. Interest and collection charges require an enforceable contractual or statutory basis. Hawaii Revised Statutes section 478-2 provides a ten percent annual rate for specified categories of debt where no different rate is established by an express written contract, but entitlement and the commencement of interest depend on the statutory category and circumstances. It does not create an automatic charge on every invoice from the day it is issued. Any agreed rate must comply with applicable law. Collection costs, attorney’s fees and compound interest are recoverable only where authorized and within the applicable limits. Unsupported administrative penalties and duplicate recovery are not permitted. A genuine billing dispute must be considered on its merits.

10. Exceptional events affecting performance
A party may rely on this section only where an event beyond its reasonable control prevents the affected performance despite reasonable preventive and mitigating measures. The party must notify the other promptly, explain the effect on the campaign and take reasonable steps to limit disruption. Relief is confined to the obligations and period actually affected. Increased expense, reduced profitability, ordinary staffing difficulties or an unexplained subcontractor failure do not automatically qualify. Cyber incidents, outages and other disruptions must be assessed against the circumstances and precautions reasonably required. Alternative performance that materially changes the contract requires agreement. If an interruption defeats an essential campaign purpose or prevents delivery within the agreed period, the client may terminate the affected undelivered portion and receive the refund due, subject to lawful accounting for services already supplied. Any separate defense of impossibility, impracticability or frustration is determined under the applicable law and is not established merely by invoking this section.

11. Applicable version and changes to these terms
The version properly incorporated when the contract is formed governs that contract. Publication of revised terms does not retrospectively amend an accepted campaign. Changes to an existing agreement require the parties’ agreement unless an enforceable contractual provision or applicable law permits the particular change. Material amendments must be explained in a form the client can retain, including their effect and proposed commencement. Silence or continued access to a public webpage does not, by itself, establish agreement to a new price, additional charge or reduced service. Mandatory legal changes apply according to their own provisions. Recurring campaigns, automatic renewals and continuous services require clear advance disclosure of the price, billing frequency, duration and cancellation arrangements. Where applicable, the Restore Online Shoppers’ Confidence Act requires disclosure of material terms, express informed consent and a simple means of stopping recurring charges. Hawaii Revised Statutes section 481-9.5 imposes additional requirements within its scope, including applicable consent, acknowledgement and cancellation information. For qualifying contracts with an initial term of at least twelve months and renewal for more than one month, the required reminder must be provided between thirty and sixty days before the cancellation deadline. Material changes must be notified as required by law. A single advertising order does not authorize recurring billing unless that arrangement has been validly agreed.

12. Consumer cancellation rights
There is no general fourteen-day cancellation right under United States federal law or Hawaii law merely because an advertising service was ordered online. Business advertising purchases ordinarily do not qualify for consumer cancellation protections. Particular transactions may nevertheless fall within Hawaii Revised Statutes Chapter 481C, the Federal Trade Commission’s Cooling-Off Rule or another applicable statute. Where a qualifying cancellation right exists, the supplier must provide the required information and notices and honor the right within its legal scope. The three-business-day periods applicable to certain covered transactions are governed by each regime’s own definitions, conditions and exceptions; the federal and Hawaii rules must not be treated as identical. A contractual cancellation right expressly offered in an accepted proposal remains binding independently of any statutory right.

Starting work during an applicable cancellation period
Where a statutory cancellation period applies, beginning design work, preparing materials or launching an advertisement does not automatically extinguish the right. Any early-performance request, waiver or exception must satisfy the actual requirements of the governing law. A general statement that a campaign is urgent, customized or nonrefundable is insufficient where the law requires more. The supplier must not make deductions from a statutory refund unless the applicable law permits them. Any separate contractual permission to begin work must clearly explain its financial consequences without misrepresenting or restricting mandatory rights.

Separate deliverables and refunds
An order may include advertising placement, creative production and separately licensed digital material. Their treatment depends on the agreed transaction and applicable law; describing every deliverable as "digital content" does not create a cancellation exception. Following a valid statutory cancellation, reimbursement must meet the relevant legal deadline. Where Hawaii Revised Statutes section 481C-2 applies, its refund requirements, including the applicable ten-business-day period, govern. Any lawful deduction must be explained. Refunds will ordinarily use the original payment method unless another method is agreed or necessary for a lawful, practical reason. No administrative refund charge will be imposed where prohibited. Collection by an authorized payment recipient does not extend a statutory deadline or release the supplier from reimbursement obligations.

How to cancel
A cancellation request may be sent to [email protected] or to the supplier’s correspondence address in section 13. Any other legally permitted method remains available. The client should identify the campaign and, if available, the order reference so that the request can be processed accurately. No particular wording is required where the applicable law permits an unambiguous cancellation statement. A request may state: "Please cancel my advertising order and stop any future renewal charges. Please confirm the effective cancellation date and any refund due." Statutory rules determine whether timely dispatch or receipt is required. This example does not replace any cancellation notice or form that the supplier is legally required to provide.

13. Addresses and contact details
The advertising supplier and contracting party may be contacted at its operational and correspondence address:

SCANDIC TRUST GROUP LLC
IQ Business Centre
Bolsunovska Street 13–15
01014 Kyiv / Ukraine
Email: [email protected]
Website: www.HonoluluBulletin.com
Legal form: limited liability company incorporated under Ukrainian law
Registration number: 1010351020000018952

The registered office and company address is:

SCANDIC TRUST GROUP LLC
Oksamytova Street 1-b, Office 30
Sofiivska Borshchahivka
Kyiv Region - 08147 / Ukraine

Technical operation and administration are provided within the scope of appointment by:

SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2
Dubai - 342001 / United Arab Emirates
Telephone: +971 54 221 5217

The Ukrainian registration number is not represented as a United States or Hawaii company registration number. Contractual notices, complaints and refund requests may be addressed to the supplier using the contact details above. Special legal requirements for service of proceedings remain unaffected.

14. Backups and retention of information
Campaign materials, correspondence, delivery records and accounting information will be retained only for the purposes and periods reasonably required for performance, administration, compliance and the establishment, exercise or defense of legal claims. Routine administrative personal information will ordinarily be deleted or anonymized when no longer needed and no later than twelve months after campaign completion and final settlement, unless a longer period is justified by a specific legal obligation, unresolved dispute or other documented lawful necessity. This is a contractual retention policy, not a universal statutory period for tax, accounting or evidential records. Preservation obligations arising from existing or reasonably anticipated litigation must be respected. Backups must have appropriate security, restricted access and a defined deletion or overwrite cycle. Restoring a backup does not authorize unrelated reuse or disregard of an applicable deletion restriction. External processing and international transfers must satisfy the legal and contractual requirements applicable to the information. Further details are provided in the Privacy Policy.

15. Technical systems and security commitments
The supplier must maintain technical and organizational measures appropriate to the services and the risks involved. Measures may include access controls, secure transmission, monitoring, vulnerability management, backups and incident response. No system is represented as immune from interruption or attack. Where a particular security product, certification or assurance level is expressly agreed, the contractual documentation must identify the relevant product, version, configuration, evaluation scope and supporting evidence. A Common Criteria certificate, including one referring to Evaluation Assurance Level 7, concerns the defined evaluated product and configuration; it must not be presented as certification of the entire publication, hosting environment or advertising service without supporting evidence. An agreed security requirement may not be silently replaced with a lower specification. Security incidents must be addressed promptly, with notifications made where required by applicable law or contract, including Hawaii’s security breach notification requirements where their conditions are met.

16. Measurement, reach and assessment of results
Campaign measurement must distinguish the following concepts:

- Page impressions: recorded displays of webpages under the stated methodology; a page impression does not establish that a particular advertisement was displayed.
- Advertising impressions: recorded displays of the advertisement under the agreed delivery and counting rules.
- Viewable impressions: impressions meeting expressly identified visibility criteria and measurement requirements.
- Unique visitors or reach: estimates produced by the stated methodology; a device, browser or identifier does not necessarily correspond to one individual.
- Clicks and interactions: measured events whose definition, filtering and attribution must be explained where they affect reporting or payment.
- Conversions: defined outcomes attributed under the agreed method and attribution period, subject to the limits of the available evidence.

The order must identify the metrics determining delivery and invoicing, the measurement system, relevant time zones and material limitations. CPM means the price per 1,000 valid advertising impressions under the agreed methodology; page impressions are not substituted without express agreement. Identified invalid or fraudulent traffic must not be billed as valid delivery. Accreditation or independent verification must not be claimed without a substantiated basis covering the relevant service. Differences caused by privacy choices, advertising blockers or measurement methods require proper assessment and do not automatically defeat a reasonable billing challenge. Seasonal changes and fluctuating news interest do not release the supplier from a guaranteed delivery commitment.

17. Orders and prices
Advertising orders concern www.HonoluluBulletin.com unless additional publications or channels are expressly identified in the accepted order. The minimum order value for business and professional clients is EUR 5,500 before applicable taxes. Business prices stated in sections 17 to 20 are exclusive of applicable taxes and any separately disclosed, lawfully agreed tax reimbursement. The currency remains euros unless another currency is expressly agreed. Any conversion method and client-borne payment or bank charges must be disclosed before acceptance. Tax treatment depends on the actual transaction, relevant nexus, supplier and customer status and applicable law. Hawaii’s general excise tax is imposed on taxable business activity and must not be misrepresented as a conventional sales tax imposed directly on the customer. Any permitted contractual pass-through must be accurately described and disclosed before the client commits to payment. Receipt of funds through Germany does not automatically make German value added tax applicable. A consumer must receive an offer stating the final amount payable, including applicable taxes and unavoidable charges. Services involving contextual targeting, search optimization, remarketing or behavioral targeting must be expressly described and performed lawfully. Inability to use an unlawful or unauthorized method does not automatically create a right to payment for an undelivered service.

18. Premium placements and special advertising formats
Subject to availability and the accepted campaign specifications, options may include:

- Rotating placements within relevant subject areas, including business, motoring, information technology and telecommunications.
- Rotation across additional publications or websites expressly named in the order.
- An additional reminder button measuring 160 × 50 pixels at a CPM of EUR 5, before applicable taxes for business and professional orders.
- Combinations of formats and placements under an individual proposal.
- Display advertising, Medium Rectangle placements and video, subject to agreed dimensions, functionality and technical requirements.

The offer must identify available inventory, campaign duration, audience criteria, measurement basis and compatibility requirements. Exclusivity or continuous visibility on every device is promised only where expressly agreed. Any such commitment forms part of the supplier’s binding obligations. A format name or industry specification does not dispense with the need to identify the actual deliverable.

19. Annual volume discounts
The following discounts apply to one client’s total eligible advertising order value within the same calendar year, calculated before the annual discount and excluding taxes:

- From EUR 15,000: 3.5%.
- From EUR 50,000: 5%.
- From EUR 100,000: 11%.
- From EUR 150,000: 16%.
- From EUR 250,000: 21%.
- From EUR 500,000: 30%.

The rate for the highest attained band applies to the entire eligible annual volume; the percentages are not cumulative. Service exclusions or additional eligibility conditions must be disclosed and validly agreed before the affected order is accepted. Final reconciliation must account for discounts already credited, cancellations and refunds, with sufficient information to verify the calculation. Where an advance discount depends on a binding annual commitment, a shortfall adjustment requires a previously agreed lawful mechanism and must be confined to the difference between the discount granted and the discount earned. No adverse adjustment may be imposed to the extent that the supplier caused the shortfall. Reconciliation must not unlawfully penalize the exercise of statutory rights.

20. Campaign reporting, invoicing and agency commission
Usage-based invoicing must be supported by a campaign report using the agreed metrics. The client may request an explanation of discrepancies and submit relevant evidence from another measurement system. The supplier’s report is evidence of performance, not conclusive proof that cannot be challenged. Prompt notice assists correction during the campaign, but a claim does not lapse merely because it is raised after final reporting. For an order introduced through an advertising agency, the agency commission is 10% of the invoiced advertising service price after agreed discounts and before taxes, unless another basis is expressly agreed. The proposal must identify the entitled agency and explain how the commission is settled. The same commission or discount must not be counted twice on the same basis. An agency must disclose whether it acts in its own name or for a named principal and must comply with applicable duties concerning authority, conflicts and commission disclosure. Joint liability of an agency and its client is not created merely by the agency submitting an order.

21. Advertising formats
Depending on availability, compatibility and the agreed service, the following formats may be offered:

- Rotating horizontal display advertising, including Full Banner.
- Superbanner.
- Layered formats and interactive HTML5 advertising.
- Pop-up and pop-under formats where lawful and supported by the relevant browser.
- Content Ads placed near editorial material with clear advertising identification.
- Vertical display formats, including Skyscraper.
- Advertising information strips, including Newsticker formats.
- Advertising bars, including Ad Bars.
- Expandable corner formats, including Page Peel.
- Interstitial and Superstitial formats.
- Video and other expressly agreed multimedia formats.

Presentation must respect applicable privacy choices, child protection requirements and reasonable user control. Deceptive buttons, false system warnings, undisclosed charges, circumvention of browser security and unjustified obstacles to closing an advertisement are prohibited under these terms. Accessibility must be considered in design and delivery, including obligations under the Americans with Disabilities Act and Hawaii law where applicable. Essential disclosures must remain understandable and usable and must not depend solely on inaccessible animation, sound or interaction. An industry guideline or accessibility standard must not be described as legally binding in every circumstance or as certification of the entire service without a proper basis.

22. Clients, businesses and consumers
A client is the person or organization entering into the advertising contract. A business client purchases advertising for commercial or professional purposes. Consumer status depends on the governing statute and the actual transaction. Hawaii Revised Statutes section 480-1 defines a consumer by reference to a natural person’s purchase or attempted purchase primarily for personal, family or household purposes, or the person’s commitment of money, property or services in a personal investment. This does not make every commercial advertising purchaser a consumer. Status is not determined solely by an email address, invoice heading or declaration in these terms. Different statutes have their own definitions, thresholds and exemptions. No person is required by these terms to surrender a status or protection conferred by mandatory law.

23. Attachments and contractual documentation
Campaign specifications, schedules, artwork approvals, price lists, technical requirements and data processing arrangements form part of the contract only where properly identified and incorporated. Material documents must be accessible before acceptance and supplied or confirmed in a retainable form where required by law or the agreed process. Individually agreed campaign provisions take precedence over inconsistent standard provisions, subject to mandatory law. An attachment must not conceal an additional charge, materially reduce a disclosed deliverable or introduce an unexpected restriction without adequate notice and agreement. A document supplied after formation does not automatically amend the contract. Operational correspondence may clarify performance without changing the agreed commercial substance.

24. Contracting parties and allocation of responsibilities
The advertising contract is between the identified client and SCANDIC TRUST GROUP LLC. SCANDIC ASSETS FZCO performs appointed technical functions, and LEGIER Beteiligungs mbH receives authorized payments and handles advertising enquiries within its authority. Each company remains responsible for obligations arising from its own activities and undertakings. Delegating performance does not itself release the supplier. Substitution of another contracting party requires the legal steps and any consent necessary for an effective transfer of obligations; it must not be achieved merely by changing an invoice heading or website notice. An assignment of rights must comply with applicable law and must not unlawfully diminish the client’s remedies or protections. Appointment of a foreign technical provider or collection agent does not, by itself, alter the agreed governing law.

25. Invalid, unfair or unincorporated provisions
The effect of an invalid, unenforceable, unconscionable or unincorporated provision is determined by applicable law. Any severance must be consistent with the governing legal rules and must not preserve an agreement in a form that the law does not permit. The remaining provisions continue only to the extent legally appropriate in the circumstances. An ineffective term is not automatically replaced with whichever provision would produce the greatest economic advantage for the supplier. Nothing in this section authorizes the supplier to rewrite an agreement unilaterally, waive another party’s statutory rights or enforce a restriction contrary to public policy.

26. Governing law, jurisdiction and dispute resolution
These terms and contracts governed by them are subject to the law of the State of Hawaii and applicable United States federal law, without excluding mandatory requirements that apply under the relevant conflict-of-laws rules. This choice does not determine the law governing every corporate, tax, employment or regulatory matter involving the participating companies. Jurisdiction and venue are determined by applicable legal rules. These terms impose no exclusive foreign forum, compulsory arbitration, class-action waiver or waiver of trial by jury. Contractual complaints may be submitted to [email protected]. The supplier will consider the complaint and explain its position and any proposed remedy. Use of this contact procedure is not a mandatory barrier to legal proceedings, does not shorten a statutory limitation period and does not prevent an application for urgent relief. Matters may be referred to the Hawaii Office of Consumer Protection, the Federal Trade Commission, the Hawaii Campaign Spending Commission, the Federal Election Commission or another competent authority within its jurisdiction. Those authorities have different powers and do not automatically adjudicate private contractual refund claims. Participation in private advertising self-regulation or alternative dispute resolution is not represented as mandatory or established unless a valid legal or contractual basis exists.

Contact:
"HONOLULU STAR-BULLETIN"
Email: [email protected]

Last updated: 1 November 2026.