Sanqto Terms of Service

1. The Sanqto application screens customers (natural persons and businesses) against public sanctions lists — to support the Customer in meeting obligations under EU Regs. 269/2014 and 833/2014 and the Polish Act of 13 April 2022 on special measures for preventing support for the aggression on Ukraine. The application is intended for professional (B2B) use. It may also be used by sole traders with consumer-equivalent rights.
2. The service provider is JDG ALEXSOFT Alexander Kolesnikov, registered office at 55-100 Brochocin 16/2, NIP 9521934827, REGON 526448288 (the "Provider").
3. The Provider can be contacted by:
   1. email — contact@sanqto.com,
   2. postal mail — at the registered office in §1(2) above,
   3. phone — +48 881 658 757, Mon–Fri 9:00–17:00 CET.
4. Under Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market for Digital Services (the "DSA"), the Provider has appointed a contact point for direct communication with EU member-state authorities, the European Commission, the Digital Services Board, and Customers — at contact@sanqto.com.
5. Before using the application, the Customer must read these Terms and the Privacy Policy.

Capitalised terms in these Terms have the following meanings:

1. Application — the Sanqto software, including updates, installed locally on the Customer's hardware (on-premise), used to screen entities against the Reference Lists;
2. Pricing — the document or information specifying the current price of the Licence and the Maintenance Fee, and other terms set out there, available at https://sanqto.com/#cennik;
3. Consumer — a natural person concluding a legal act with the Provider that is not directly related to their business or professional activity;
4. Account — the application's admin panel created locally on the Customer's side and the corresponding licence record kept by the Provider, enabling the Customer to use the Application;
5. Reference Lists — lists of sanctioned entities, in particular lists published under EU Regs. 269/2014 and 833/2014, UN sanctions, OFAC, and the Polish MSWiA national list, distributed by the Provider as digitally signed files;
6. Non-conformity — non-conformity of the Service with the contract within the meaning of Art. 43k(1)–(2) of the Polish Consumer Rights Act;
7. Trial Period — a 30-day period during which the Customer may use the Service free of charge, in order to evaluate the Application;
8. Maintenance Period — the period during which the Provider provides Maintenance; the first Maintenance Period is 12 months and is included in the Licence Fee, and each subsequent one covers 12 months and is payable under the Pricing;
9. Licence Fee — the one-time fee paid by the Customer for the grant of a perpetual licence to use the Application, set in line with the Pricing in force at the time of order;
10. Maintenance Fee — the fee for each Maintenance Period following the first, set in line with the Pricing;
11. Maintenance — the Provider's service comprising delivery of Reference List updates, Application updates, and technical support;
12. Review — a Customer review of the Application, describing their experience with the Service;
13. Privacy Policy — the document containing information about the processing of personal data of Customers by the Provider, available at https://sanqto.com/en/privacy/;
14. Sole trader with consumer-equivalent rights — a natural person running a business who concludes a contract directly related to that business, where it is clear from the contract that it does not have a professional character for them (Art. 38a of the Polish Consumer Rights Act);
15. Terms — these Terms;
16. Customer Content — any data (including personal data), files, information, and materials saved by the Customer locally within the Application and provided to the Provider in the course of support contacts;
17. Contract — the contract for delivery of a digital service within the meaning of the Polish Consumer Rights Act, concluded between the Provider and the Customer;
18. Use of Application Service / Service — the digital service consisting of enabling the Customer to use the Application's functionality, together with delivery of Application updates and Reference List updates;
19. Customer — a customer (a business, a sole trader with consumer-equivalent rights, or a Consumer) using the Application;
20. Provider — defined in §1(2) of these Terms;
21. Consumer Rights Act — the Polish Act of 30 May 2014 on consumer rights;
22. Electronic Services Act — the Polish Act of 18 July 2002 on the provision of services by electronic means.

1. To use the Application properly, the Customer needs together:
   1. a device (computer, workstation, or server) running Windows 10/11, macOS 12+, or Linux with kernel 5.x or newer,
   2. at least 4 GB of RAM and 2 GB of free disk space,
   3. temporary internet access — solely to download Application updates and Reference Lists,
   4. an active email account for licence handling.
2. The Application runs fully offline after the first licence activation and the first Reference List download. The screening function does not require a connection to the Provider's servers.
3. The Customer must not use the Application with viruses, bots, worms, or other computer code, files, or programs (in particular, scripts and applications that automate processes, or other code, files, or tools).
4. The Provider notes that distribution of Application updates and Reference Lists uses transport-layer cryptographic protection (TLS 1.3) and digital signatures on reference files. Communication is one-way: Provider's server → Customer's Application.
5. The Provider notes that despite the security measures applied, internet use and electronic services may be exposed to malicious software reaching the Customer's IT system and device. To minimise this risk, the Provider recommends using antivirus software and keeping the operating system up to date.
6. Use of the Application is paid, except during the Trial Period referenced in §4.
7. The Customer using the services must provide only data (including company and contact-person data) that is true. The Provider is not liable for the consequences of the Customer providing false or incomplete data.

1. Under the Contract, the Provider enables the Customer to use the Application's functionality within the scope of the chosen tier in the Pricing and delivers Application updates and Reference Lists.
2. To conclude a Contract during the Trial Period, the Customer should:
   1. visit https://sanqto.com and complete the contact form in the "Contact" section,
   2. tick the box confirming they have read these Terms and the Privacy Policy and accept their provisions,
   3. click the "Book a call" button,
   4. receive the install package, the Trial Period licence key, and installation instructions from the Provider.
3. Activation of the licence key in the installed Application is equivalent to entering into a free Trial Period Contract for 30 days.
4. After the Trial Period, the Customer may decide to acquire a perpetual licence to use the Application, which is equivalent to concluding a paid Contract per the Pricing (which sets the scope of features, the Licence Fee, and the Maintenance terms).
5. To acquire the licence, the Customer, no later than 30 days after activating the Trial Period, picks a tier in the Pricing and concludes the Contract by accepting the offer the Provider sends by email and paying the Licence Fee under §5.
6. The licence to use the Application is granted perpetually. Upon payment of the Licence Fee, the Customer acquires the right to use the Application with no time limit, within the scope of the chosen Pricing tier; the first Maintenance Period of 12 months is included in the Licence Fee.
7. The Customer keeps any data and configuration entered into the Application during the Trial Period — that data is stored only locally on the Customer's side and is never copied by the Provider.
8. The Provider notes, and the Customer acknowledges, that maintaining conformity of the Service with the Contract requires installing the Application updates and Reference List updates supplied by the Provider. The Provider supplies Reference List updates at least once per hour, and Application updates quarterly or as technically needed, during the current Maintenance Period.
9. Sections 10–17 below apply only to Customers that are Consumers or sole traders with consumer-equivalent rights.
10. If the Customer is not given access to the Service immediately after concluding the Contract, the Customer calls upon the Provider to grant access immediately. The call may be sent by email to the address in §1(3)(1). If the Provider does not grant access immediately after receiving the call, the Customer may withdraw from the Contract.
11. Notwithstanding (10), the Customer may withdraw from the Contract without a prior call if at least one of the cases listed in Art. 43j(5) of the Consumer Rights Act applies.
12. Notwithstanding (10)–(11), the Customer may at any time terminate the Contract by uninstalling the Application and emailing the Provider a termination notice to the address in §1(3)(1).
13. Withdrawal from or termination of the Contract is by way of a notice given to the Provider. The notice may be sent by email to the address in §1(3)(1).
14. If the Customer breaches these Terms and does not remedy the breach despite a call to do so, the Provider may terminate the Contract on 7 (seven) days' notice by sending an email notice to the Customer. After the notice period, the Provider deactivates the licence key.
15. The Provider deactivates the licence key promptly after receiving a Customer's termination notice or at the end of the notice period.
16. Deactivation of the licence key does not automatically delete data stored locally in the Application on the Customer's side. The Customer is the sole controller of their data and is responsible for archival and deletion in line with their own procedures and applicable law (including the 5-year report retention obligation under AML rules).
17. The Customer keeps all data and reports generated locally in the Application during the Contract. That data was never sent to the Provider and remains under the Customer's sole control.

1. Prices in the Pricing are stated net of VAT. Payment is made in euro (EUR) or Polish złoty (PLN). The applicable VAT rate is added to the Licence Fee and the Maintenance Fee per applicable law.
2. All amounts payable to the Provider are paid by the Customer by bank transfer to the account stated on the invoice or via the available online payment system.
3. For the grant of the licence, the Customer pays a one-time Licence Fee, and for each subsequent Maintenance Period, the Maintenance Fee, in the amounts in the Pricing. Changes to prices are announced in the Application and on the Provider's website and do not constitute amendments to these Terms.
4. The payment date is the date the amount due is credited to the Provider's bank account. Once the payment is credited, the Provider sends the Customer a VAT invoice by email and activates the licence key.
5. The Licence Fee is paid once, against an invoice, before the licence key is activated. The Maintenance Fee for a subsequent Maintenance Period is paid in advance for that period.
6. If the Licence Fee is not paid, the licence key is not activated until the payment is credited. If the Maintenance Fee for a subsequent Maintenance Period is not paid, then from the start of that period the Provider stops supplying Reference List and Application updates; the perpetual licence to use the Application remains in force. Maintenance resumes once the overdue Maintenance Fee is credited.

1. The current Pricing is at https://sanqto.com/#cennik.
2. Tiers: Starter, Business, Enterprise. Enterprise is on a custom quote.
3. During the Trial Period the Customer uses the Application free of charge.
4. The Provider may change the Pricing at any time.
5. A Pricing change does not affect the Licence Fee set in Contracts concluded before the change. The Maintenance Fee for a subsequent Maintenance Period is set under the Pricing in force when that period begins.

1. This section applies only to Consumers and sole traders with consumer-equivalent rights.
2. The Service the Provider delivers must conform to the Contract for the entire delivery period.
3. The Provider is liable for any Non-conformity arising during the Service delivery period.
4. Where a Non-conformity arises, the Customer may file a complaint requesting that the Service be brought into conformity with the Contract.
5. Complaints are filed by email to the address in §1(3)(1).
6. A complaint should include:
   1. the Customer's first and last name and (if applicable) company name,
   2. email address,
   3. description of the Non-conformity (including, where possible: Application version, operating system, steps to reproduce),
   4. request to bring the Service into conformity with the Contract.
7. The Provider may refuse to bring the Service into conformity if doing so is impossible or would cost the Provider disproportionately.
8. After examining the complaint, the Provider replies stating one of:
   1. the complaint is upheld and the planned date for bringing the Service into conformity,
   2. refusal under (7) above,
   3. rejection of the complaint as unfounded.
9. The Provider responds within 14 (fourteen) days of receiving the complaint, by email.
10. If a complaint is upheld, the Provider brings the Service into conformity at its own cost, within a reasonable time and without undue inconvenience to the Customer. In practice this is delivered as an Application patch or a Reference List correction.
11. Where a Non-conformity arises, the Customer may declare withdrawal from the Contract if:
    1. bringing the Service into conformity is impossible or would cost disproportionately,
    2. the Provider has not brought the Service into conformity per (9),
    3. the Non-conformity persists despite the Provider's attempts,
    4. the Non-conformity is so material that it justifies withdrawal without prior request,
    5. it is clear from the Provider's statement or from circumstances that the Provider will not bring the Service into conformity in a reasonable time or without undue inconvenience.
12. The withdrawal notice may be sent by email to the address in §1(3)(1).
13. If the Customer withdraws from the Contract, the Provider deactivates the licence key promptly after receiving the withdrawal notice.
14. Under Art. 34(1a) of the Consumer Rights Act, on withdrawal the Customer must stop using the Service and stop making it available to third parties.

1. This section applies only to Businesses other than sole traders with consumer-equivalent rights.
2. If the Service does not conform with these Terms, the Customer may file a complaint.
3. Complaints are filed in writing or by email to the address in §1(3)(1), no later than 30 days after the non-conformity becomes apparent.
4. A complaint should include:
   1. the Customer's name and tax ID,
   2. email address of the contact person,
   3. description of the non-conformity.
5. The Provider may refuse to bring the Service into conformity if doing so is impossible or would cost disproportionately.
6. After examining the complaint, the Provider replies stating one of:
   1. the complaint is upheld and the planned date for bringing the Service into conformity,
   2. refusal under (5) above,
   3. rejection of the complaint as unfounded.
7. The Provider responds within 21 (twenty-one) days of receiving the complaint, by email. In particularly complex cases this period may be extended to 30 calendar days, with notice to the Customer.

1. Under Art. 27 et seq. of the Consumer Rights Act, a Customer who is a Consumer or a sole trader with consumer-equivalent rights has the right to withdraw from the Contract without giving any reason within 14 (fourteen) days of conclusion.
2. The Provider extends the 14-day right of withdrawal also to Businesses other than sole traders with consumer-equivalent rights — for the first Contract concluded with the Provider.
3. The right of withdrawal is exercised by giving the Provider a withdrawal notice. Sending the notice before the deadline in (1) is enough to meet it.
4. The withdrawal notice may be made in any form, in particular on the form set out in Annex 2 to the Consumer Rights Act.
5. On receipt of a withdrawal notice the Provider promptly emails an acknowledgement to the Customer.
6. If the Customer withdraws from the Contract, the Provider deactivates the licence key promptly upon receiving the notice and refunds all payments received from the Customer within 14 days of receiving the notice.

1. The Customer may send the Provider a Review of the Application and the Service.
2. Reviews may be sent in any way, including by email.
3. Sending a Review does not oblige the Provider to publish it. The Provider may remove any Review it has published at any time.
4. The following Reviews are not allowed:
   1. Reviews containing untrue data, contrary to law, these Terms, or good practice,
   2. Reviews containing content for unlawful activity, inciting violence, hate, or insulting any person or group,
   3. Reviews infringing personal rights, copyright, the right to one's image, or other third-party rights,
   4. Reviews promoting activity competing with the Provider.
5. Anyone may report a Review that may breach these Terms. Reports go to contact@sanqto.com and should include reasons, the exact location of the Review, and the reporter's contact details (first and last name or company name, plus email).
6. The Provider examines reports within 14 days and informs the reporter and the Review's author of the decision and its reasons. Both the reporter and the author may appeal by email within 14 days of the decision; the appeal is examined within a further 14 days by an authorised team without automated decision tools.
7. By sending a Review, the Customer declares that they are its sole author and grants the Provider a free, non-exclusive, time- and territory-unlimited licence to use it in promotional materials. The licence covers minor edits needed for distribution without changing the substance.

1. The Provider undertakes to deliver the Service with due care.
2. The Provider ensures that servers distributing the Reference Lists are available 99.5% per calendar month. The maximum length of a single service window is 4 hours. Planned service windows occur on Saturdays between 23:00 and 04:00 local time (CET/CEST), with 7 days' notice by email.
3. Given the on-premise model, the Provider is not responsible for the availability or performance of the Application running on the Customer's hardware. Server infrastructure, backups, and network configuration sit with the Customer.
4. The parties exclude the Provider's liability for lost profits of a Customer that is a Business.
5. The Provider does not guarantee a specific level of performance, efficiency, or fitness of the Application for the Customer's specific needs and use cases. In particular, the screening result is a tool supporting the Customer's decision on sanctions compliance — the final decision (e.g. refusing service, filing a report with the FIU) sits with the Customer and requires legal assessment in the specific facts.
6. To the extent allowed by the Polish Civil Code and the Consumer Rights Act, the Provider is not liable to the Customer for the consequences of:
   1. using any Application functionality contrary to its intended purpose,
   2. providing incorrect or untrue data,
   3. access credentials being used by third parties where those third parties obtained the credentials due to disclosure or insufficient security on the Customer's side,
   4. the Customer not installing Application updates and Reference Lists per §4(8),
   5. the Customer's breach of statutory sanctions obligations.
7. To the extent allowed by law, the Provider is not liable for Application disruptions caused by:
   1. force majeure (including unavailability of key external suppliers),
   2. necessary service work,
   3. causes on the Customer's side,
   4. causes outside the Provider's control, in particular acts of third parties.
8. After the Contract ends, the Provider:
   1. keeps the licence record and invoice history for the period required by tax law (5 years),
   2. has no access to operational data stored locally on the Customer's side — the Customer is the sole controller of that data.

1. All elements of the Application, in particular:
   1. the Application name and the Sanqto trademark,
   2. the Application logo and graphic materials,
   3. the Application source code and binaries,
   4. fuzzy-match algorithms and Reference List comparison logic,
   5. technical documentation and training materials,
   are protected under the Polish Act of 4 February 1994 on copyright and related rights, the Polish Act of 30 June 2000 on industrial property law, the Polish Act of 16 April 1993 on combating unfair competition, and other generally applicable laws, including EU law.
2. Under the Contract, the Provider grants the Customer a non-exclusive, non-transferable, perpetual licence, limited territorially to the Customer's premises, to use the Application — solely within the scope of the chosen Pricing tier and per the Application's intended purpose.
3. Any use of the Provider's intellectual property outside the licence, without the Provider's prior express consent, is forbidden. In particular, decompilation, disassembly, reverse engineering, sublicensing, sale or making available to third parties, and copying the Application other than for backup purposes are forbidden.

1. This section applies only to Consumers and sole traders with consumer-equivalent rights.
2. A Customer who is a Consumer or a sole trader with consumer-equivalent rights may use out-of-court complaint and claim mechanisms.
3. Detailed information on out-of-court mechanisms is available at the seat of and on the websites of:
   1. district (city) consumer ombudsmen and social organisations whose statutory tasks include consumer protection,
   2. Voivodeship Inspectorates of Trade Inspection,
   3. the Office of Competition and Consumer Protection (https://uokik.gov.pl).
4. The EU Online Dispute Resolution platform is at https://ec.europa.eu/consumers/odr.

1. Given the on-premise model, the Application processes the Customer's customer data locally only, on the Customer's hardware and network. The Provider is not a processor of that data within the meaning of GDPR Art. 28 and has no access to it.
2. The Provider processes only personal data of contact persons on the Customer's side (representatives, Account administrators, persons authorised to file complaints) — for the purposes of concluding and performing the Contract, billing, and post-sale support.
3. Detailed information on the Provider's processing of personal data is in the Privacy Policy at https://sanqto.com/en/privacy/.
4. The Customer, as the controller of the data of customers screened in the Application, is solely responsible for meeting information obligations toward those customers (GDPR Art. 13) and for the legal basis of the processing (under GDPR Art. 6(1)(c) — compliance with a legal obligation to which the controller is subject).

1. This section applies only to Consumers and sole traders with consumer-equivalent rights.
2. The Provider may change the Service if:
   1. the Application needs to be adapted to new operating system or server environment versions used by the Customer,
   2. the Provider decides to improve the Service by adding new features or modifying existing ones,
   3. there is a legal obligation to make changes, including alignment with the law (e.g. changes to EU sanctions regulations or to the implementing acts of the Act of 13 April 2022).
3. A Service change cannot involve any additional cost for the Customer during the current Maintenance Period.
4. The Provider notifies the Customer of a Service change via a notice in the Application panel (after an update is pulled) and by email.
5. If the Service change materially and negatively affects access to the Service, the Provider informs the Customer of:
   1. the nature and date of the change,
   2. the Customer's right to terminate the Contract with immediate effect within 30 (thirty) days of the change.
6. The Provider sends the notice in (5) by email no later than 7 (seven) days before the change.
7. Termination is by way of a notice given to the Provider by email.

1. The Provider may amend these Terms if:
   1. the Provider's business changes,
   2. new services are launched, existing services modified, or services discontinued,
   3. a technical change to the Application requires an update to these Terms,
   4. there is a legal obligation to make changes, including alignment with the law.
2. Customers will be notified by publishing the amended version on the website and in the Application panel. Independently, the amended version is sent to the Customer by email to the contact person.
3. Contracts concluded before the change are governed by the previously applicable Terms — until the end of the current Maintenance Period.
4. A Customer that does not agree to a change may terminate the Contract with immediate effect within 14 (fourteen) days of receiving notice. Failure to terminate is treated as acceptance.
5. Termination is by way of an email notice to the Provider at the address in §1(3)(1).
6. The Provider deactivates the licence key promptly upon receiving a notice under (5).

1. The current version of these Terms is in force from 3 May 2026.
2. These Terms are governed by Polish law. Any disputes are first settled by amicable negotiation, and failing that:
   1. for Consumers and sole traders with consumer-equivalent rights — before the court having jurisdiction under generally applicable law,
   2. for other Businesses — before the common court having jurisdiction over the Provider's registered office.
3. Matters not covered by these Terms are governed by generally applicable Polish law, in particular the Civil Code, the Consumer Rights Act, and the Electronic Services Act.