# ENCY EXTENSION STORE — PUBLISHING POLICY **Version 1.0** **Effective Date: 1 November 2026** **Publisher: ENCY SOFTWARE LTD, Registration No. HE 460544, 9 Aiolou and Panagioti Diomidous, Katholiki, 3020 Limassol, Cyprus** --- ## 1. INTRODUCTION AND STATUS OF THIS POLICY ### 1.1 Purpose This Publishing Policy (the **"Policy"**) sets out the rules that apply to the submission, review, distribution and continued availability of Extensions on the ENCY Extension Store (the **"Store"**), operated by ENCY Software Ltd (**"ENCY"**, **"we"**, **"us"**). ### 1.2 Contractual status This Policy is incorporated by reference into, and forms an integral part of, the **ENCY Extension Store Developer Agreement** (the **"Developer Agreement"**) entered into between ENCY and each developer publishing an Extension (a **"Developer"**, **"you"**). By accepting the Developer Agreement and by submitting an Extension, you agree to comply with this Policy as in force at the relevant time. A breach of this Policy constitutes a breach of the Developer Agreement. ### 1.3 Relationship to other documents | Document | Governs | |---|---| | Developer Agreement | Contractual relationship, IP, liability, fees, termination, governing law | | This Publishing Policy | Content, technical and commercial rules for Extensions | | Schedule A — Reserved Functionality Domains | The list of ENCY core and separately licensed capabilities | | Schedule B — Technical Requirements | SDK, API, packaging, signing and security requirements | | Schedule C — Enforcement and Appeals Procedure | Graduated enforcement, statements of reasons, appeals | In the event of conflict, the Developer Agreement prevails over this Policy, and this Policy prevails over the Schedules, save that Schedule A prevails in respect of the scope of Reserved Functionality. ### 1.4 Changes to this Policy We may amend this Policy from time to time. Except where paragraph 1.5 applies, we will give you **not less than 15 days' notice** of any amendment, by email to your registered address and by publication in the Developer Portal, before the amendment takes effect. If you do not accept an amendment, you may withdraw your Extensions and terminate the Developer Agreement during the notice period. Continued publication after the effective date constitutes acceptance. **Amendments do not apply retroactively.** No amendment will be applied to conduct occurring before its effective date. ### 1.5 Exceptions to the notice period We may implement a change with immediate effect where we are subject to a legal or regulatory obligation requiring us to do so, or where an immediate change is necessary to address an unforeseen and imminent danger relating to security, fraud, malware, spam, data breach or other cybersecurity risk. ### 1.6 Definitions **"Extension"** — any software component, plug-in, script, module, integration, content pack or other item submitted by a Developer for distribution through the Store. **"Platform"** — the ENCY software products with which Extensions interoperate, including ENCY, ENCY Robot, ENCY Tuner, ENCY Hyper, ENCY Clouds and MachineMaker, in each case including their respective SDKs and APIs. **"Reserved Functionality"** — the capabilities listed in Schedule A. **"Separately Licensed Module"** — a component of Reserved Functionality that ENCY licenses to end users for a separate charge or under a distinct licence entitlement. **"Entitlement"** — a valid, active end-user licence issued through the ENCY licensing system granting access to a specified Separately Licensed Module. **"Gated Extension"** — an Extension operating within a Reserved Functionality Domain that is made available under paragraph 4.3. --- ## 2. ELIGIBILITY AND ACCOUNT ### 2.1 Who may publish Publication is open to legal entities and to individuals acting in a business capacity. You must: (a) provide accurate and complete identity, contact, tax and, where applicable, VAT details, and keep them current; (b) complete our verification process, including sanctions and export-control screening; (c) hold all rights necessary to distribute the Extension and to grant the licences contemplated by the Developer Agreement; (d) not be established in, or controlled from, a jurisdiction in respect of which distribution would breach applicable sanctions or export-control law. ### 2.2 Accuracy of information You must notify us within 15 days of any material change to the information provided under paragraph 2.1, including change of control of your business. --- ## 3. GENERAL CONTENT AND CONDUCT REQUIREMENTS An Extension must not: (a) infringe the intellectual property rights, trade secrets or other rights of any person, including ENCY; (b) contain malware, spyware, ransomware, cryptominers, backdoors or any undisclosed code that operates against the interest of the end user; (c) circumvent, disable, weaken, emulate, replace or interfere with the ENCY licensing system, activation, entitlement enforcement, digital signing or anti-tamper mechanisms, or facilitate any of the foregoing; (d) collect, transmit or process end-user data other than as disclosed in the Extension's privacy disclosure and as permitted by applicable data-protection law; (e) misrepresent its origin, authorship, functionality, performance or compatibility, or falsely suggest that it is produced, endorsed or certified by ENCY; (f) use ENCY trade marks, logos or product names other than in accordance with our Trade Mark Guidelines, and in particular must not incorporate "ENCY" into the Extension's own name in a manner suggesting first-party origin; (g) be materially non-functional, unmaintained, or duplicative of another Extension published by the same Developer without a genuine distinguishing purpose; (h) breach applicable law, including export-control, sanctions, competition and consumer-protection law; (i) generate, transmit or execute machine-control output in a manner that bypasses the Platform's validation, simulation or collision-checking pipeline where the Platform provides such validation for the operation concerned. --- ## 4. RESERVED FUNCTIONALITY AND ENTITLEMENT GATING > This Section 4 is the core of the Policy. It is written to be read and applied literally. ### 4.1 What Reserved Functionality is, and why it exists Certain capabilities are delivered by ENCY as core components of the Platform or as Separately Licensed Modules. These are listed in **Schedule A** (each a **"Reserved Functionality Domain"**). Reserved Functionality Domains are those capabilities in respect of which ENCY: (a) performs integrated development, validation, verification and certification against machine kinematics and controller behaviour; (b) carries first-line and escalation support responsibility toward the end user and, where applicable, toward the end user's machine tool builder; (c) bears product-safety and output-integrity responsibility for the results produced; and (d) enforces end-user access through the ENCY licensing system. The designation of a Reserved Functionality Domain reflects these integration, validation, support and safety responsibilities. It is **not** a commitment by ENCY to refrain from competing, nor a restriction on any Developer's freedom to develop, publish or sell software outside the Store. **Schedule A is descriptive, not exhaustive.** A capability is Reserved Functionality where, at the relevant time, ENCY licenses it to end users under a distinct licence entitlement, whether or not it is yet listed in Schedule A. Schedule A records the Domains identified to date and is updated as the product line develops. Where a capability meets that description but is not yet listed, ENCY will list it under paragraph 4.7 before relying on it as a ground for refusal or enforcement, save that the absence of a listing does not permit a Developer to publish an Extension that circumvents an Entitlement then being issued by ENCY. A Developer in doubt should use the pre-submission determination procedure in paragraph 4.6. ### 4.2 The general rule An Extension operating within a Reserved Functionality Domain may be published on the Store **only** in accordance with paragraph 4.3 (Entitlement-Gated Publication) or paragraph 4.4 (Complementary Extensions). An Extension must not be designed, packaged, marketed or operated so as to enable an end user to obtain the outcome of a Separately Licensed Module **without holding a valid Entitlement** to that Module. **Capability tiers.** Where Reserved Functionality is licensed in tiers of increasing capability, the Entitlement required is the Entitlement for the **tier at which the capability is licensed by ENCY**, and not any lower tier. Accordingly, an Extension delivering a capability that ENCY licenses at a higher tier must verify the Entitlement for that higher tier, notwithstanding that the end user holds a valid Entitlement to a lower tier of the same Domain. A lower-tier Entitlement does not satisfy the gating condition for a higher-tier capability. **Illustration.** Simultaneous multi-axis milling is licensed by ENCY under the 5-Axis Mill Entitlement. An Extension delivering simultaneous multi-axis toolpaths must verify the 5-Axis Mill Entitlement. It may not be made available to an end user holding only a 3-Axis Mill Entitlement, and may not be structured, configured or documented so as to permit such use. ### 4.3 Entitlement-Gated Publication — the permitted route ENCY **welcomes** Extensions that offer alternative or specialised implementations within a Reserved Functionality Domain, including implementations by established technology vendors, provided they are published as **Gated Extensions**. A Gated Extension: (a) **is conditioned on the end user holding a valid Entitlement** to the corresponding Separately Licensed Module identified in Schedule A. The Extension will not install, activate or execute where no such Entitlement is present; (b) enforces that condition through the ENCY entitlement-verification API provided in the SDK, and not through any independent or substitute mechanism; (c) is presented in the Store, and must be marketed by the Developer, as an **alternative or additional capability available to licensed users** of the corresponding Module, and not as a replacement for, or a means of avoiding the purchase of, that Module; (d) may be offered free of charge or for a separate charge, in addition to the end user's ENCY licence fee, on the commercial terms agreed under the Developer Agreement; (e) is subject to the technical and validation requirements in Schedule B applicable to its Domain, including where applicable output-verification and simulation-pipeline requirements. **Illustration.** A Developer offering an independently developed multi-axis milling toolpath engine may publish it as a Gated Extension tied to the ENCY 5-Axis Mill Entitlement. An end user holding an ENCY 5-Axis Mill licence may then install and use that engine as an alternative strategy set alongside the ENCY implementation. An end user without that licence cannot obtain the Extension. The Extension thereby extends choice for licensed users rather than displacing the licensed Module. ### 4.4 Complementary Extensions — expressly permitted Extensions that **complement** Reserved Functionality are permitted without gating and are expressly encouraged, including Extensions that: (a) prepare, import, translate or condition inputs consumed by Reserved Functionality; (b) post-process, analyse, report on, visualise or export outputs produced by it; (c) automate, batch, schedule or orchestrate workflows that invoke it; (d) integrate the Platform with third-party systems (ERP, MES, PLM, PDM, tool-management, measurement, simulation or slicing systems); (e) address machining strategies, materials, processes, machine types or use cases not covered by Reserved Functionality. ### 4.5 Assessment criteria In determining whether an Extension falls within paragraph 4.2, we will assess, on the basis of the Extension as submitted and as marketed: (a) whether it delivers materially the same end-user outcome as a Separately Licensed Module; **and** (b) whether an end user could, by using it, obtain that outcome without holding the corresponding Entitlement; **and** (c) how it is positioned, described and priced by the Developer. An Extension satisfying (a) will not be refused where it is published as a Gated Extension under paragraph 4.3. An Extension satisfying (a) **and** (b) will be refused publication or, if already published, will be subject to Section 6. ### 4.6 Pre-submission determination Before investing development effort, a Developer may request a written determination as to whether a proposed Extension falls within a Reserved Functionality Domain, and if so on what gating conditions it may be published. We will respond within **20 business days** of receiving a complete description. A determination is binding on ENCY for **24 months** from the date given, and will not be reversed by a subsequent amendment to Schedule A, **provided that**: (a) the description supplied by the Developer was complete and accurate in all material respects; (b) the Extension as submitted does not differ materially in capability, output or intended use from the description on which the determination was given; and (c) the Extension is not subsequently modified, configured, documented or marketed in a manner that would have altered the determination had it been disclosed. A determination ceases to bind ENCY, with immediate effect and without prejudice to our rights under Section 6, where any of (a) to (c) is not satisfied. A determination does not authorise circumvention of the ENCY licensing system and confers no protection in respect of conduct falling within paragraph 4.9 or paragraph 3(c). A determination relates only to the Reserved Functionality assessment. It is not an approval of the Extension, and does not limit refusal or enforcement on any other ground under this Policy, Schedule B or applicable law. We strongly encourage use of this procedure. Where a Developer has obtained a determination and developed in reliance on it, we will not refuse publication on Reserved Functionality grounds inconsistent with that determination. ### 4.7 Changes to Schedule A The notice period for an amendment to Schedule A depends on its effect: | Type of amendment | Notice | |---|---| | (i) **Clarifying** — renaming a Domain, restructuring or subdividing an existing Domain by capability tier, correcting a reference, or recording an Entitlement identifier, in each case without extending the scope of what is reserved | **15 days** | | (ii) **Recording an existing Entitlement** — listing a capability for which ENCY was already issuing a distinct end-user Entitlement at the date of the amendment | **15 days** | | (iii) **Extending scope** — reserving a capability that was not previously Reserved Functionality and for which no distinct Entitlement was being issued | **30 days** | Where an amendment has more than one effect, the longer period applies to the amendment as a whole. An amendment of type (i) or (ii) does not enlarge what is reserved: in case (i) the scope is unchanged, and in case (ii) the capability was already Reserved Functionality under paragraph 4.1 by reason of the Entitlement being issued. The shorter period reflects that. Where an Extension already published in compliance with this Policy would, as a result of an amendment of type (iii), fall within a Reserved Functionality Domain: (a) the amendment does **not** apply to that Extension for a period of **12 months** from the effective date of the amendment; (b) during that period we will work with the Developer in good faith to agree a transition, which may include conversion to a Gated Extension, technical adaptation, a commercial arrangement under paragraph 4.8, or an extended transition period; (c) the Developer may in any event continue to support existing end users of that Extension for the remainder of their then-current licence terms. **Limits of the transition period.** The protection in (a) applies only to an Extension that was, at the time of publication, genuinely compliant with this Policy. It does **not** apply where: (i) the Extension was published in breach of paragraph 4.2 as it stood at the time of publication; (ii) the Extension was published following a determination under paragraph 4.6 that has ceased to bind ENCY under that paragraph; (iii) the Extension circumvents, or its continued availability would circumvent, the ENCY licensing or entitlement system, including by delivering a capability for which ENCY was already issuing a distinct Entitlement at the time of publication; (iv) the Developer declines to engage with the transition discussion under (b), or engages otherwise than in good faith; or (v) the Extension is the subject of a repeated-infringement determination under Schedule C. In any case falling within (i) to (v), the amendment applies on its effective date and Section 6 is available without the transition period. **Grandfathering does not suspend other grounds.** The transition period relates only to the Schedule A amendment. It does not prevent restriction, suspension or removal on any other ground under this Policy, including paragraph 3(c) (licensing-system circumvention), paragraph 4.9 (anti-circumvention) or paragraph 6.3 (immediate action). ### 4.8 Commercial alternatives to removal Where an Extension falls within paragraph 4.2 but delivers genuine value to end users, we may offer the Developer the opportunity to discuss: (a) conversion to a Gated Extension under paragraph 4.3; (b) a distribution, OEM or revenue-share arrangement; (c) technical partnership or certification; (d) acquisition or licensing of the Extension or its underlying technology. Neither party is obliged to reach agreement, and neither party is obliged to enter into discussion. This paragraph confers no right on a Developer to require ENCY to negotiate, and does not limit our rights under Section 6. **Discussions do not suspend enforcement.** Where a discussion under this paragraph is opened, the measures in Section 6 and the periods in paragraph 6.1 continue to run unless ENCY agrees otherwise in writing. Any suspension of enforcement during discussions is a concession, is effective only if given in writing, and may be withdrawn on 10 days' notice. Where the Extension circumvents the ENCY licensing or entitlement system, or falls within paragraph 4.9, ENCY will not ordinarily offer a discussion under this paragraph and is under no obligation to do so. ### 4.9 Scope limitation and anti-circumvention **Scope.** Nothing in this Section 4 restricts a Developer from developing, publishing, marketing or selling any software through any channel other than the Store. This Section governs the conditions of distribution **through the Store only**. **Anti-circumvention.** The limitation above does not permit a Developer to achieve indirectly what paragraph 4.2 prohibits directly. Accordingly, a Developer must not, through any channel: (a) distribute a component that interoperates with the Platform and that delivers the outcome of a Separately Licensed Module to an end user who does not hold the corresponding Entitlement, where that component relies on the Platform's SDK, APIs, extension interfaces or documented integration points; (b) distribute an off-Store component whose function is to supply, complete, unlock, extend or re-enable capability in an Extension published on the Store, in a manner that defeats the gating condition applicable to that Extension; (c) publish a compliant Extension on the Store and direct, refer or market end users to an off-Store component that would not itself be publishable under paragraph 4.2. This paragraph is directed solely at the integrity of the ENCY licensing and entitlement system. It does **not** restrict the development, publication, marketing or sale of standalone software, of software integrating with any third-party platform, or of software that does not rely on the Platform's SDK, APIs or extension interfaces. A Developer's freedom to compete with ENCY outside the Store is unaffected. --- ## 5. SUBMISSION, REVIEW AND PUBLICATION ### 5.1 Review Each Extension and each update is subject to review for compliance with this Policy and Schedule B. We aim to complete review within **10 business days** of a complete submission. ### 5.2 Outcome We will notify you of the outcome in writing. Where an Extension is refused, the notification will state: (a) the specific provision of this Policy or Schedule B relied on; (b) the facts and circumstances, including where relevant any third-party notice or technical finding, that led to the decision; (c) what change would enable the Extension to be published, where such a change is possible; (d) how to seek review under Schedule C. ### 5.3 Ranking and presentation Our approach to ranking and presentation in the Store, and any differentiated treatment of ENCY's own products, is set out in Section 8. --- ## 6. ENFORCEMENT ### 6.1 Graduated approach Where we consider an Extension or a Developer to be in breach, we will apply the least intrusive measure appropriate to the breach, escalating only as necessary: | Stage | Measure | Notice | |---|---|---| | 1 | Written notice with statement of reasons and opportunity to remedy | Remedy period of not less than **30 days** | | 2 | Removal from featured placement, curated collections and search promotion | Concurrent written notice | | 3 | Suspension of new installations; existing installations continue to operate | Concurrent written notice | | 4 | Removal of the Extension from the Store | Not less than **30 days'** prior notice | | 5 | Termination of the Developer Agreement and closure of the Developer account | Not less than **30 days'** prior notice | Escalation need not be sequential. We will select the stage appropriate to the nature and seriousness of the breach, and may proceed directly to a higher stage where a lower stage would not address it. ### 6.1A Interim suspension of distribution Where we have reasonable grounds to consider that an Extension circumvents the ENCY licensing or entitlement system, including by falling within paragraph 4.2 (capability tiers) or paragraph 4.9 (anti-circumvention), we may apply **Stage 3** with immediate effect, so that no further installations occur, pending completion of the procedure in this Section. Interim suspension under this paragraph: (a) takes effect on notice, with a statement of reasons under paragraph 6.2; (b) does not affect installations already made, which continue to operate; (c) is a protective measure and not a determination of breach; (d) is reviewed on the Developer's request within **10 business days**, and is lifted if the grounds are not made out; (e) is without prejudice to the Developer's right of appeal under Schedule C. This paragraph exists because a breach of the entitlement conditions causes loss with each new installation, and that loss is not remedied by later removal. It is limited to suspension of new distribution and does not extend to removal or termination, which remain subject to the notice periods in paragraph 6.1. ### 6.2 Statement of reasons Before, or at the latest at the time when, any restriction, suspension or removal takes effect, we will provide you with a statement of the reasons for that decision on a durable medium, in accordance with paragraph 5.2(a)–(d). ### 6.3 Immediate action We may act immediately, and the notice periods in paragraph 6.1 do not apply, where: (a) the Extension contains malware or presents an imminent security, safety or data-protection risk to end users; (b) continued distribution would place ENCY in breach of a legal or regulatory obligation, a court order or an applicable sanctions or export-control regime; (c) we receive a credible third-party intellectual-property infringement notice and the Developer has not responded within the period stated in the notice; (d) the Developer has repeatedly infringed this Policy in a manner giving rise to a repeated-infringement determination under Schedule C; (e) the Extension, or a component distributed by the Developer, defeats, bypasses, spoofs or disables the ENCY licensing, activation, entitlement-verification or anti-tamper systems, or the Developer has falsified information material to a determination under paragraph 4.6. Where we act under this paragraph, we will provide the statement of reasons under paragraph 6.2 without undue delay. ### 6.4 Reinstatement Where a decision to restrict, suspend or remove is reversed, whether on appeal or otherwise, we will reinstate the Extension without undue delay, including restoring the Developer's access to data held in the Developer Portal as it stood immediately before the decision took effect. ### 6.5 Effect on end users Removal of an Extension does not of itself terminate licences already granted to end users. Section 7 of the Developer Agreement governs continuity of support for existing end users following removal. --- ## 7. COMPLAINTS AND DISPUTE RESOLUTION ### 7.1 Internal complaints Any Developer may submit a complaint concerning a decision taken under this Policy to **developers@encycam.com**. Complaints are handled free of charge. We will acknowledge within 5 business days and provide a reasoned response within **20 business days**. ### 7.2 Mediation ENCY qualifies as a small enterprise within the meaning of Commission Recommendation 2003/361/EC and is accordingly not required to designate mediators under Article 12 of Regulation (EU) 2019/1150. We are nevertheless willing to consider mediation of any dispute on a case-by-case basis, and will engage in good faith with any reasonable proposal. ### 7.3 Rights preserved Nothing in this Section limits any right a Developer may have to bring proceedings before a competent court, or to bring or participate in proceedings under Article 14 of Regulation (EU) 2019/1150. --- ## 8. RANKING, PRESENTATION AND DIFFERENTIATED TREATMENT ### 8.1 Main ranking parameters Extensions are ranked in Store listings and search results principally by reference to the following parameters, in descending order of relative importance: 1. **Relevance** to the end user's query, installed products and licensed Modules; 2. **Quality signals** — end-user ratings, uninstall rate, crash and error telemetry, support responsiveness; 3. **Compatibility** with the end user's Platform version and machine configuration; 4. **Maintenance currency** — recency of updates, SDK version targeted; 5. **Adoption** — installation volume, normalised by category and time since publication; 6. **Certification status** under Schedule B. Payment does not influence organic ranking. Paid promotional placement, if offered, is separately and clearly labelled as such. ### 8.2 Differentiated treatment of ENCY's own products We disclose the following, in accordance with Article 7 of Regulation (EU) 2019/1150. ENCY's own first-party components and Separately Licensed Modules receive the following differentiated treatment relative to third-party Extensions: (a) they may be presented within the Platform user interface in positions not available to third-party Extensions, including as default or pre-installed capabilities; (b) they are not subject to the review process in Section 5; (c) they may use Platform interfaces not exposed in the public SDK, where required for core product function; (d) within a Reserved Functionality Domain, a third-party Extension is subject to the entitlement-gating condition in paragraph 4.3, whereas the corresponding ENCY Module is not. **Essential considerations underlying this treatment.** ENCY bears integrated development, validation, certification, product-safety and end-user support responsibility for the Platform and its Modules, including responsibility toward machine tool builders for kinematic and controller correctness; ENCY's licensing system is the mechanism by which end-user entitlements across the Platform are administered; and first-party components form part of the Platform itself rather than being distributed as separate items through the Store. ### 8.3 No most-favoured-nation restriction We do not restrict Developers from offering their products on more favourable terms through other channels, including their own websites or other marketplaces, save that a Gated Extension published on the Store must, on the Store, be offered on the gating terms set out in paragraph 4.3. --- ## 9. DATA ### 9.1 Data available to Developers The Developer Portal provides Developers with access to: installation and uninstallation counts, version-adoption data, end-user ratings and written reviews, crash and error telemetry for their own Extensions, and payout and transaction records. ### 9.2 Data available to ENCY ENCY has access to the data described in paragraph 9.1 in respect of all Extensions, together with Store-wide aggregate usage and search data. ### 9.3 Personal data Each party acts as an independent controller in respect of personal data it processes in connection with the Store, save where the Developer Agreement provides otherwise. Developers must publish a privacy disclosure for each Extension that processes personal data and must comply with Regulation (EU) 2016/679 where applicable. --- ## 10. COMMERCIAL TERMS Fees, revenue share, payment processing, taxes, refunds and chargebacks are governed by the Developer Agreement and the Commercial Schedule to it. --- ## 11. GENERAL ### 11.1 Governing law This Policy is governed by the laws of the Republic of Cyprus, as further provided in the Developer Agreement. ### 11.2 Language This Policy is published in English. Any translation is provided for convenience; the English text prevails. ### 11.3 Contact **ENCY SOFTWARE LTD** 9 Aiolou and Panagioti Diomidous, Katholiki, 3020 Limassol, Cyprus Registration No. HE 460544 · VAT No. CY 60079628L developers@encycam.com · +357 95 907793 --- *End of Publishing Policy v1.0*