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Atbion OÜ is committed to making Votinova accessible to as many people as possible, regardless of their abilities or the assistive technology they use.

Accessibility is applied on a proportionality basis: the measures described in this policy are adopted to the extent that they are reasonable and technically feasible for an interactive presentation and real-time voting software service, and some of them are voluntary in nature, beyond what is strictly required by the applicable legislation. Where an improvement would impose a disproportionate burden, Atbion OÜ will endeavour to offer an alternative means of access in accordance with section 7.

Atbion OÜ — a private limited company (Osaühing) incorporated under Estonian law, with registry code 16890390, VAT number EE102728154 and registered office at Ahtri tn 12, Kesklinna linnaosa, Tallinn 15551, Harju maakond, Estonia — is responsible for Votinova (votinova.com).

This policy takes the following legal and technical framework as a reference:

• Directive (EU) 2019/882, on the accessibility requirements for products and services (European Accessibility Act, EAA), and its transposition into Estonian law.
• Standard EN 301 549, which sets out the accessibility requirements applicable to information and communication technology products and services in the European Union.
• Web Content Accessibility Guidelines (WCAG) 2.2, published by the World Wide Web Consortium (W3C), as a conformance target at their level AA.

The stated objective of Atbion OÜ is to achieve conformance with WCAG 2.2 level AA on the surfaces listed in section 3.

This policy applies to the Votinova surfaces with which end users interact:

• The presenter dashboard — the web interface from which the presenter creates, imports and runs presentations and interactive sessions.
• The results screen — the full-screen view that is projected and displays the aggregated results in real time.
• The web join and voting experience (/join) — the flow by which the audience joins a session and responds from the browser.
• The mobile application — the application with which participants join sessions and vote from their devices.

The content provided by users themselves (presentations, images, questions and answers) depends on whoever creates it; Atbion OÜ cannot guarantee its accessibility, but it makes available to presenters features that make it easier to create accessible content.

Atbion OÜ applies, in general, the following accessibility measures across the service surfaces:

• Keyboard navigation — the main flows can be traversed and activated with the keyboard, without the need for a mouse, with a consistent focus order.
• Visible focus indicator — interactive elements display a clearly perceptible focus when navigating with the keyboard.
• Colour contrast — efforts are made to maintain a sufficient contrast ratio between text and its background, and not to convey information by colour alone.
• Alternative text — significant graphic elements incorporate descriptive alternative text.
• Screen reader compatibility — the semantic structure of the content (headings, regions and lists) is designed to be interpreted by the most common assistive technologies.
• ARIA labels — ARIA attributes and roles are used where necessary to describe interactive components and dynamic states, such as real-time results updates.
• Legible text sizes — texts support enlargement and remain legible when the text size or browser zoom is increased.
• Accessible forms and messages — input fields are associated with their labels, and error and status messages are communicated in a perceptible manner.
• Responsive design — the interfaces adapt to different screen sizes and orientations.

These measures are reviewed and reinforced on an ongoing basis in accordance with section 10.

Votinova is currently considered partially conformant with WCAG 2.2 level AA. This means that the service meets most of the applicable criteria, but some parts may not fully comply with them, as detailed in section 6.

Atbion OÜ is actively working towards full conformance with WCAG 2.2 level AA. The objective is to achieve such conformance, across all the surfaces listed in section 3, before 31 December 2026.

Atbion OÜ honestly acknowledges that, despite the measures adopted, some parts of the service may not yet be fully conformant and are in the process of being remedied. In particular:

• Certain results visualisations (for example, word clouds, heatmaps over images or dynamic charts) present information in an essentially visual manner, and their accessible equivalent is under continuous improvement.
• The content that presenters import or create (presentations, images and third-party files) may not meet the accessibility criteria, as it lies outside the direct control of Atbion OÜ.
• Some real-time interactive components may require additional adjustments to optimise the experience with assistive technologies.

These limitations are documented internally, prioritised and addressed within the framework of the continuous improvement plan. If a user encounters a barrier that is not listed here, they may report it in accordance with sections 7 and 9.

If a user encounters an accessibility barrier that prevents them from using a Votinova feature, Atbion OÜ will provide reasonable means to facilitate access to the affected information or functionality by an alternative route.

• The support team can assist and guide the user in completing a specific task.
• Where appropriate, an equivalent alternative will be offered to access the information or the service.
• Atbion OÜ will assess the request and propose a solution within a reasonable period, having regard to the proportionality criterion described in section 1.

To request alternative access, you may write to accessibility@votinova.com or use the Platform's help system.

The Accessibility Officer of Atbion OÜ coordinates the application of this policy, the monitoring of known limitations and the handling of requests and complaints.

• Accessibility email: accessibility@votinova.com
• Postal address: Atbion OÜ, Ahtri tn 12, Kesklinna linnaosa, Tallinn 15551, Harju maakond, Estonia

Atbion OÜ endeavours to respond to accessibility communications within a reasonable period from their receipt.

Atbion OÜ welcomes feedback on the accessibility of Votinova, as it helps to improve the service.

9.1. To report an accessibility barrier, make a suggestion or submit a complaint, the user may contact accessibility@votinova.com indicating, as far as possible, the affected surface (presenter dashboard, results screen, web join and voting experience, or mobile application), a description of the problem and the assistive technology used.

9.2. Atbion OÜ will acknowledge receipt of the communication within 5 business days, assess the reported barrier and propose a solution or an alternative means of access within a reasonable period.

9.3. If the user is not satisfied with the response, they may contact the Estonian authority competent for the enforcement of the European Accessibility Act: Tarbijakaitse ja Tehnilise Järelevalve Amet (TTJA) (Consumer Protection and Technical Regulatory Authority) — Endla 10A, Tallinn — https://www.ttja.ee.

Atbion OÜ evaluates the accessibility of Votinova on a periodic basis, through a combination of automated reviews, manual testing and user feedback. The results of these evaluations feed into the continuous improvement plan and the updating of the known limitations.

This policy is reviewed at least once a year and whenever significant changes occur in the service or in the applicable legal framework.