Regulations

Terms of service www.sygnanet.pl

valid from 20.05.2021

I. Terms and conditions of use

1. Terms and conditions of use www.sygnanet.pl determines the conditions for the provision of Services by the Service Provider, in accordance with the provisions of the Act of 18 July 2002 on provision of services by electronic means, including the principles of use of the Site, the scope of Service Provider's liability, the principles of the complaint procedure (hereinafter „Regulations”).

II. The Service Provider makes the following Services available electronically:

1. forwarding of the Report by the Whistleblower to the Entrepreneur

2. access to the Entrepreneur's Account

3. access to the Entrepreneur Panel

4. providing the Whistleblower with the Entrepreneur's response to its Submission.

III. Definitions

1. Pricing - pricelist of Entrepreneurial Services (Attachment No. 1)

2. Entrepreneur's account - the Entrepreneur's account created on the Website after Registration

3. Entrepreneur Panel - a panel located in the Entrepreneur's Account, where there is a list of Entries

4. Entrepreneur - a natural person, a legal person, a public entity or an organisational unit which is not a legal person and to which the law confers legal capacity, to which the Reports relate

5. Recipient of reports (Recipient) - person(s) authorised by the Entrepreneur to operate the Entrepreneur's panel on the Website. Different roles and permissions can be created for Recipients.

6. Terms and conditions - terms and conditions of use www.sygnanet.pl

7. Registration - registration means entering the information into the Entrepreneur's account on the site required to launch the Entrepreneurial Service

8. Service - website available at www.sygnanet.pl

9. Whistleblower - a user making an Report through the Service

10. The service - service consisting in the possibility of making an anonymous Declaration, access to the Entrepreneur's Account, access to the Entrepreneur's Panel, possibility of replies by the Entrepreneur via the Service

11. Agreement - agreement for the provision of Services concluded between the Service Provider and the Entrepreneur by accepting the Terms and Conditions.

12. Service provider - Specfile Project Sp. z o.o. 60-408, Poznań, ul. Nagórskiego 3, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court Poznań-Nowe Miasto and Wilda in Poznań, VIII Commercial Division of the National Court Register, NIP: 7811950934, KRS: 0000694508, bank account: 68 1090 1346 0000 0001 3490 9296

13. User - a person visiting the pages of the Service, including the Whistleblower and the Recipient

14. Report - anonymous information transmitted by the Whistleblower to the Entrepreneur concerning the Entrepreneur via the Website.

IV. General provisions

1. These Terms of Use set out the terms and conditions for the use of the Website.

2. The Service provides the Whistleblower with a possibility to submit Reports concerning the Entrepreneur, and the Entrepreneur can review the Report and respond to the Whistleblower's Report.

3. Only the Whistleblower and Recipients designated by the Entrepreneur have access to the content of the Report.

4. Submitting a Report is completely anonymous. The Service does not register any data of the Whistleblower, allowing to determine his/her identity or location, unless the Whistleblower himself/herself places such data in the content of the Notification.

5. The possibility of reporting is free of charge for the Whistleblower.

6. The Service for Entrepreneur is chargeable and its provision takes place in accordance with the Price List. The first Fee is collected upon registration of the first Recipient designated by the Entrepreneur on the Website, and each subsequent Fee is collected upon renewal of the Account on the Website in accordance with the then applicable Price List. It is permissible to use the Website free of charge for a period of 14 days from registration.

V. Starting to use the Service by the Whistleblower

1. The whistleblower, by starting to use the Service, confirms knowledge of the Regulations and accepts the provisions of the Regulations.

2. The Whistleblower is not a party to the Agreement.

VI. Establishment and termination of the contract by the Entrepreneur

1. Upon Registration, the Entrepreneur confirms that he/she has read and accepts all the provisions of the Rules and Regulations.

2. When registering, the Entrepreneur provides the following data:

   • the company name of the Entrepreneur,

   • company address,

   • NIP,

   • Recipient's data (name, company e-mail address),

   • a password to access the Entrepreneurial Service on the Website,

3. The Entrepreneur registers an Account on the main page of the Website. As a result of registration, the Entrepreneur enters an Electronic Contract with the Service Provider. The Contract is concluded for an indefinite period. Regulations are an integral part of the Contract.

4. The Entrepreneur registers on the Website a Recipient responsible for maintaining the Entrepreneur's Account, including access to Requests, and responding to Requests by providing his/her company email address The Recipient registered first becomes the Principal Recipient of Reports. He/she is entitled to share the Entrepreneur account with other people. The different roles of Recipients and their rights are detailed in the Entrepreneur panel The Recipient registered first becomes the Principal Recipient of Reports. He/she is entitled to share the Entrepreneur account with other people. The different roles of Recipients and their rights are detailed in the Entrepreneur panel.

5. The Recipient registered first becomes the Principal Recipient of Reports. He/she is entitled to share the Entrepreneur account with other people. The different roles of Recipients and their rights are detailed in the Entrepreneur panel.

6. During Registration, the Entrepreneur agrees with the Service Provider on the address of a website dedicated on the domain of the Website exclusively for the Entrepreneur's company. Notifications of Whistleblowers placed on the form of this page are forwarded to the Recipient designated in the company of this Entrepreneur. It is the Entrepreneur's responsibility to communicate the address of this website to his/her employees.

7. The Entrepreneur authenticates the Registration on the Website by transferring the Fee from a company bank account.

8. The parties are entitled to terminate the contract with 14 days' notice. The fee paid by the Entrepreneur may be reimbursed by the Service Provider in proportion to the unused period if the termination is due to the fault of the Service Provider, due to a change in the Terms and Conditions or for reasons other than those attributable to the Entrepreneur.

9. The Service Provider is entitled to terminate the Service Agreement without notice, with immediate effect, if the Entrepreneur or the Recipient breaches the Terms and Conditions. The fee paid by the Entrepreneur is then not refundable. The Entrepreneur is entitled to archive his/her Reports within 14 days.

VII. Conditions for the provision of the Service

1. As part of the Services of the Website provided to the Entrepreneur, the Whistleblower may make anonymous Submissions concerning the Entrepreneur via the Website.

2. As part of a submission the Whistleblower can create a text message and add attachments to it. After sending a notification the Whistleblower receives a document confirming sending and receiving the notification by the Recipient. The message is given an individual ID number and a password to access the Notification.

3. The Whistleblower's message is encrypted on the Whistleblower's computer and sent to the Service Provider's server. Mail notifying of a new Notification is sent from the Service Provider's server to the Recipient.

4. The notification is anonymised - all data which could serve to establish the identity or location of the Algorithm are permanently deleted from the Service Provider's Server and the Entrepreneur only has access to the anonymised notification without any personal data of the Algorithm (unless the Algorithm puts it himself in the content of the notification or in the documents attached to it).

5. The Recipient receives information on his e-mail about a Request concerning the Entrepreneur, which is on the Server in the Entrepreneur Panel.

6. In the Entrepreneur Panel, there is a list of Submissions that only the Recipient can download and decrypt locally on their computer to view.

7. Encryption and decryption of the Notification is performed using asymmetric encryption. Encryption and decryption are performed on the Signatory's or Recipient's computer. The Service Provider does not have any means of decrypting the Submissions stored on the Server.

8. Information on encryption keys and their handling policy is available in the Privacy Policy.

9. A notification has an individual ID number visible to the Recipient and the Whistleblower.

10. The Recipient in the Entrepreneur Panel has the possibility to create a response to the Request.

11. The Recipient's answer is assigned to the same individual ID number assigned to the Notification.

12. The Whistleblower is able to read the message from the Recipient on the Service Provider's page intended for responses to Whistleblowers after entering the individual ID number and password that have been assigned to the Notification.

13. The Whistleblower must check the Service Provider's website for a response to its Submission. The Whistleblower has no way of receiving feedback from the Service Provider on the response to his/her Submission, because the Service Provider does not have his/her personal or contact details (e.g., e-mail or telephone address or IP address).

VIII. Rights and obligations in relation to use of the Service

1. The Entrepreneur, the Recipient and the Whistleblower are obliged to use the Service of the Website in a manner compliant with legal regulations and good manners.

2. The Entrepreneur, the Recipient and the Whistleblower undertake not to deliver illegal content via the Website.

3. The Entrepreneur and the Recipient undertake to ensure the confidentiality of access data to the Service, in particular the password and individual Report ID, and to prevent unauthorised persons from obtaining access data necessary for using the Service.

4. The Whistleblower undertakes to ensure the confidentiality of the access data to the Service, in particular the password and the individual Report ID number.

5. The Entrepreneur is not entitled to assign rights and obligations under the Contract without the prior consent of the Service Provider, expressed in writing under pain of nullity. The Entrepreneur is also not entitled to resell his Account.

6. In the event of a change in the data provided during registration by the Entrepreneur, he/she is obliged to immediately inform the Service Provider of such a change by e-mail (kontakt@sygnanet.pl). The Entrepreneur is liable in case of failure to inform the Service Provider about such changes, inter alia, for indicating an incorrect e-mail address for contact with the Recipient.

7. The Entrepreneur is obliged to inform each Recipient, on behalf of the Service Provider, of the scope of the Recipient's personal data provided and to comply, on behalf of the Service Provider, with the Service Provider's obligation to inform the Service Provider as a Personal Data Controller, as referred to in the provisions of Regulation 2016/679 of the European Parliament and of the Council of the EU of 27 April 2016. (RODO) to each Recipient.

IX. Liability

1. The Service Provider is not responsible for the content and attachments sent through the Service.

2. The Service Provider shall also not be liable for damages to the Client, the Recipient and the Whistleblower arising from:

   • misuse of the Service

   • failure of the Customer's equipment, Recipient or Whistleblower,

   • the operation of computer viruses and software installed on the computers of the Customer, the Recipient and the Whistleblower,

   • interruptions in the operation of the Website or the Service,

   • events caused by force majeure,

   • violation of the law or the Regulations by the Customer, the Recipient or the Signatory,

   • provision of access data to the Account by the Entrepreneur or the Recipient, as well as the password and individual ID number by the Whistleblower.

3. In cases caused by the Service Provider's fault, the Service Provider's liability is limited to a maximum amount equal to the fee paid by the Entrepreneur for annual use of the Site.

X. Complaint

1. The Entrepreneur and the Recipient have the right to lodge a complaint in connection with the provision of the Service by the Service Provider.

2. A complaint may be submitted to:

   • by e-mail to: kontakt@sygnanet.pl, or

   • in writing to the Service Provider's registered address: Specfile Project Sp. z o.o. 60-408, Poznań, ul. Nagórskiego 3.

3. The complaint should contain the name and surname or company name, address, contact details as well as a description of the objections and the scope of the request.

4. The Service Provider is obliged to consider the complaint within 14 days of its receipt or completion if the complaint is incomplete.

5. If a complaint is incomplete, the Service Provider will immediately notify the Client and set an appropriate time limit for its completion.

XI. Technical issues

1. The Service is provided via the Internet and is therefore subject to all the restrictions associated with its use.

2. The Service Provider does not guarantee full correctness of operation of the Service in all available varieties of operating systems and web browsers. To use the Service, at least the following technical requirements must be met:

• have a Windows XP or later computer operating system,

• use Internet Explorer, Chrome, Safari, Opera or FireFox web browser.

3. The Recipient must be registered on www.specfile.pl in order to use the Services of the Website.

XII. Personal data

1. Issues related to the processing of personal data are regulated in the Privacy Policy.

XIII. Final provisions

1. The Regulations come into force as of the date of their publication on the Website and constitute an integral part of the Service provision agreement.

2. Amendments to the Regulations shall come into force upon their publication on the Website in a manner allowing the Users to become acquainted with them. By accepting the Terms of Use, the User consents to the changes in the Terms of Use being made unilaterally by the Service Provider.

3. The Service Provider will notify the Entrepreneur of changes to the Terms and Conditions and the Price List by email to the address provided by the Entrepreneur during registration.

4. The Customer and the Service Provider will endeavor to settle any disputes by pre-judicial agreement.

5. The content of the Service Regulations and Privacy Policy are available on the main page of the Service (www.sygnanet.pl)

6. In matters not covered by these Terms and Conditions, the provisions of Polish law shall apply, in particular the Act of 23 April 1964. - Civil Code and the Act of 18 July 2002 on electronic services.

Pricing

Attachment 1