Terms of Service

1.1. These Terms of Service define the rules for using the website available at epko.tech (hereinafter: "Website") and the conditions for the provision of electronic services by EPKO sp. z o.o. 1.2. These Terms of Service have been prepared pursuant to Article 8(1)(1) of the Polish Act of 18 July 2002 on Electronic Service Provision (Journal of Laws 2020, item 344). 1.3. The owner and administrator of the Website is: EPKO Spółka z ograniczoną odpowiedzialnością (EPKO sp. z o.o.) — a Polish limited liability company ul. Podleśna 2, 05-270 Marki, Poland District Court for the Capital City of Warsaw in Warsaw, 14th Commercial Division of the National Court Register KRS: 0000908693 Tax ID (NIP): 1251720637 Statistical number (REGON): 389307530 Share capital: PLN 6,300.00 (fully paid up) 1.4. Contact with the Service Provider: • Email: biuro@epko.tech • Correspondence address: ul. Podleśna 2, 05-270 Marki, Poland 1.5. Using the Website constitutes acceptance of these Terms of Service. If you do not agree with any provision, please refrain from using the Website.

Terms used in these Terms of Service mean: 2.1. Service Provider – EPKO sp. z o.o. with its registered office in Marki. 2.2. User – any natural person, legal entity, or organizational unit without legal personality that uses the Website. 2.3. Consumer – a User who is a natural person performing a legal act not directly related to their business or professional activity (Article 221 of the Polish Civil Code). 2.4. Sole trader with consumer rights – a natural person running a sole proprietorship who enters into a contract directly related to their business activity, but which does not have a professional character for them (Article 385⁵ of the Polish Civil Code and Article 7aa of the Consumer Rights Act). 2.5. Electronic Services – services provided electronically by the Service Provider through the Website, in particular: • Providing informational content (company website, blog, case studies) • Contact form • Free compliance audit 2.6. IT Services – services provided by the Service Provider under separate agreements, including: • Website and web application development • Custom software development • Technical consulting and technical compliance reviews • Ongoing partnership packages 2.7. Agreement – a separate agreement concluded between the Service Provider and the Client, governing the detailed terms of IT Services.

3.1. To use the Website, the following are required: • A device with internet access (computer, tablet, smartphone) • A current web browser with JavaScript and cookie support • An active internet connection 3.2. The Website is optimized for digital accessibility in accordance with WCAG 2.2 Level AA guidelines, in fulfillment of obligations arising from Directive (EU) 2019/882 (European Accessibility Act – EAA) and the Polish Act of 26 April 2024 on Ensuring Compliance with Accessibility Requirements for Certain Products and Services. We strive to ensure that everyone can use it comfortably, regardless of any limitations. 3.3. Accessibility barriers and feedback mechanism: if you encounter a digital accessibility problem with any element of the Website, please write to biuro@epko.tech. Your report should include a description of the issue and your preferred contact method. We will respond within 7 days of receiving your report, and barrier removal will take place no later than within 2 months. 3.4. The Website supports light and dark modes and respects the user's system settings for reduced motion (prefers-reduced-motion).

4.1. Using the Website and Electronic Services is voluntary and free of charge. 4.2. The User agrees to use the Website in accordance with applicable law, these Terms of Service, and good practices. 4.3. The following are prohibited: • Actions that may disrupt the proper functioning of the Website • Providing unlawful content • Using the Website to send unsolicited commercial information (spam) • Attempting to gain unauthorized access to Website resources • Automated downloading of Website content (scraping) without the prior consent of the Service Provider, subject to exceptions provided by law, in particular Articles 26² and 26³ of the Polish Copyright and Related Rights Act (text and data mining for scientific research and other purposes) • Using Website content in a manner that infringes copyright Rights reservation for text and data mining (TDM): pursuant to Article 26³(4) of the Polish Copyright Act and Article 4(3) of Directive (EU) 2019/790 (DSM), the Service Provider expressly reserves all rights to the Website content with respect to text and data mining conducted for purposes other than scientific research — including the training of artificial intelligence and large language models. This reservation is also expressed in a machine-readable form in the robots.txt file and in the Website's metadata. Commercial TDM, including the use of content to train AI models, requires the prior written consent of the Service Provider. 4.4. The Service Provider may block access to the Website for a User who violates the Terms of Service, after prior unsuccessful request to cease the violations. 4.5. Single point of contact under the Digital Services Act (DSA): in accordance with Articles 11 and 12 of Regulation (EU) 2022/2065, we designate the following point of contact for Member States' authorities, the European Commission, the European Board for Digital Services, and recipients of the service: • Email: biuro@epko.tech • Correspondence address: ul. Podleśna 2, 05-270 Marki, Poland • Languages of communication: Polish or English 4.6. Reporting illegal content. The EPKO Website publishes exclusively content of the Service Provider and does not constitute a "hosting service" or "online platform" within the meaning of Articles 3(g) and 3(i) DSA. Nevertheless, as a matter of good practice and transparency, we provide a mechanism for reporting potentially illegal content: if you notice content on the Website that you consider illegal (Article 16 DSA), please submit a notice to biuro@epko.tech. The notice should include a justification, an exact indication of the content (URL), your contact details, and a statement of good faith. We will promptly confirm receipt of the notice and, no later than within 14 days of its receipt, inform the reporter of our decision together with the statement of reasons and information on available redress mechanisms (Articles 17 and 20 DSA). Notices are processed in a timely, non-arbitrary, objective and diligent manner. 4.7. Automated decision-making and artificial intelligence: in its current form, the Website does not use automated decision-making systems, profiling, or artificial intelligence systems that would produce legal effects for Users or similarly significantly affect them. Should the Service Provider introduce AI-based functionalities on the Website in the future (e.g. a chatbot, content recommendations, or an offer assistant), Users will be clearly informed in accordance with Article 50 of Regulation (EU) 2024/1689 (Artificial Intelligence Act), and any AI-generated content will be marked as artificially generated or modified.

5.1. Contact Form • The service agreement begins when the form is filled out and submitted. • The service consists of enabling the User to send a message to the Service Provider. • Submitting the form requires providing: name, email address, and message content — to the extent necessary for the Service Provider to respond, in accordance with the data minimisation principle (Article 5(1)(c) GDPR). Providing additional data is voluntary. • The service is one-time and concludes upon form submission. • A response will be sent via email within 3 business days. 5.2. Blog and Informational Content • The Service Provider publishes articles, guides, and educational materials on technology, EU regulations, and software development. • The content is informational and educational in nature. It does not constitute legal advice. • EPKO is not a law firm. We present regulatory information (WCAG, GDPR, NIS2, AI Act) from a technical perspective, as a company building software that complies with these requirements. 5.3. Free Compliance Audit • The Service Provider offers the possibility of a free compliance audit of a website or application against selected EU regulations. • The scope of the audit is determined individually after receiving the request. • The audit result is indicative and does not constitute a legal opinion.

6.1. IT Services (website development, custom development, consulting, partnership packages) are provided under separate Agreements concluded individually with the Client. 6.2. The terms of delivery, deadlines, remuneration, and scope of work are determined by each Agreement. 6.3. These Terms of Service do not govern the detailed conditions of IT Services. In the event of a discrepancy between the Terms of Service and the Agreement, the Agreement shall prevail. 6.4. The Service Provider does not provide services in the following areas: • Hosting and cloud services • Legal services and legal advice • Services for unethical industries (gambling, drugs, prostitution)

7.1. All content posted on the Website, including texts, graphics, logos, icons, photographs, video materials, graphic layout, source code, and other materials, is protected by copyright and is the property of EPKO sp. z o.o. or has been used under appropriate licenses. 7.2. The User may use the Website content solely for personal use, within the limits of permitted personal use as set out in Article 23 of the Polish Act of 4 February 1994 on Copyright and Related Rights. Copying, modifying, distributing, or publicly sharing materials from the Website for commercial purposes requires the prior written consent of the Service Provider. 7.3. The name "EPKO", logo, and graphic marks are trademarks of EPKO sp. z o.o. Their use without permission is prohibited. 7.4. Blog articles may be quoted in accordance with the right of citation (Article 29 of the Polish Copyright Act), with the mandatory indication of the source and a link to the original material.

8.1. The Service Provider makes every effort to ensure that the content published on the Website is reliable, up-to-date, and accurate. 8.2. The content on the Website is informational in nature and does not constitute an offer within the meaning of Article 66 of the Polish Civil Code, unless expressly stated otherwise. 8.3. The Service Provider is not liable for: • Interruptions in Website availability caused by force majeure, technical failures, maintenance, or third-party actions • Consequences of improper use of the Website by the User • Content posted on external websites to which links from the Website lead • Decisions made by the User based on informational content published on the Website 8.4. To the extent permitted by law, the Service Provider's liability towards Entrepreneurs is limited to damages caused intentionally. This limitation does not apply to Consumers or sole traders with consumer rights.

9.1. The User has the right to submit a complaint regarding the functioning of the Website or Electronic Services. 9.2. A complaint may be submitted: • By email to: biuro@epko.tech • By mail to: EPKO sp. z o.o., ul. Podleśna 2, 05-270 Marki, Poland 9.3. A complaint should include: • Name (or company name) and contact details • Description of the problem and the circumstances of its occurrence • Expected resolution method 9.4. The Service Provider will process the complaint within 14 days of receipt and will inform the User of its resolution by email. 9.5. Complaints regarding IT Services provided under separate Agreements are processed in accordance with the provisions of those Agreements.

10.1. The controller of Users' personal data is EPKO sp. z o.o. 10.2. The rules for processing personal data, including purposes, legal bases, retention periods, and User rights, are described in the Privacy Policy available at: epko.tech/en/privacy-policy. 10.3. Information about cookies used, cookie categories, and consent management is described in the Cookie Policy available at: epko.tech/en/cookie-policy. Cookie preferences may be changed at any time by reopening the consent banner or via browser settings — withdrawal of consent does not affect the lawfulness of processing carried out earlier on the basis of that consent. 10.4. Using the Website involves the processing of technical data (IP address, browser information). Details can be found in the Privacy Policy. 10.5. Legal bases for personal data processing under Electronic Services: • Contact form and free compliance audit request – Article 6(1)(b) GDPR (steps taken at the request of the data subject prior to entering into a contract) and Article 6(1)(f) GDPR (legitimate interest of the controller in responding to inquiries and conducting correspondence). • Newsletter (if offered) – Article 6(1)(a) GDPR (consent) together with Article 10 of the Polish Act on Electronic Service Provision and the provisions of the Polish Electronic Communications Act governing consent to the use of telecommunications terminal equipment for direct marketing purposes (this provision replaced, as of 10 November 2024, the former Article 172 of the Telecommunications Act). • Analytical and marketing cookies – Article 6(1)(a) GDPR (consent expressed via the cookie banner). In every case where processing is based on consent, the User has the right to withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal (Article 7(3) GDPR). Withdrawing consent shall be as easy as giving it. 10.6. Data subject rights under the GDPR. Every person whose data is processed by the Service Provider has, in particular, the following rights: the right of access (Article 15 GDPR), the right to rectification (Article 16 GDPR), the right to erasure (Article 17 GDPR), the right to restriction of processing (Article 18 GDPR), the right to data portability (Article 20 GDPR), the right to object to processing based on legitimate interest (Article 21 GDPR), and — where processing is based on consent — the right to withdraw it (Article 7(3) GDPR). The detailed procedure for exercising these rights, including the data required for identity verification and response deadlines, is described in the Privacy Policy. 10.7. Right to lodge a complaint with a supervisory authority. Without prejudice to the rights referred to in section 10.6, every person whose data is processed has the right to lodge a complaint with a supervisory authority — in Poland: the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl) — if they consider that the processing of their personal data infringes the GDPR (Article 77 GDPR). Persons residing in another EU Member State may lodge a complaint with the supervisory authority of the Member State of their habitual residence, place of work, or place of the alleged infringement. 10.8. Data Protection Officer. The Service Provider has not appointed a Data Protection Officer (DPO) because it does not meet the criteria set out in Article 37(1) GDPR (no large-scale systematic monitoring and no large-scale processing of special categories of data). Any matters concerning the processing of personal data may be addressed directly to the Service Provider at: biuro@epko.tech. 10.9. Transfers of data outside the European Economic Area. The Service Provider prefers to use infrastructure located within the European Economic Area (EEA) — the Website is hosted on the Service Provider's own dedicated server in the EU. Should the use of individual services (such as certain analytics, marketing or communication services) result in a transfer of data outside the EEA, such transfers take place only on the basis of appropriate safeguards, in particular adequacy decisions of the European Commission or Standard Contractual Clauses (SCCs) pursuant to Article 46 GDPR. A detailed list of recipients and destination countries is provided in the Privacy Policy.

11.1. Consumers have the right to withdraw from the electronic service agreement within 14 days of concluding the agreement, without giving a reason (Article 27 of the Polish Act of 30 May 2014 on Consumer Rights). This right also applies to sole traders with consumer rights pursuant to Article 7aa of the Consumer Rights Act. 11.2. The right of withdrawal does not apply if the Service Provider has fully performed the service with the Consumer's express consent, and the Consumer was informed before the start of the service that they would lose their right to withdraw upon its completion (Article 38(1) of the Consumer Rights Act). 11.3. The withdrawal statement may be submitted by email to: biuro@epko.tech or by mail to the Service Provider's registered address. 11.4. Sample withdrawal statement: "I, [full name], hereby withdraw from the agreement for the provision of the service [service description], concluded on [date]. Email address: [email]. Date: [date]. Signature: [signature, if sent by mail]."

12.1. Consumers have the right to use out-of-court methods of handling complaints and pursuing claims, including: • Applying to the Provincial Inspector of the Trade Inspection to initiate mediation proceedings • Applying to the permanent consumer arbitration court at the Provincial Inspector of the Trade Inspection • Applying to the Polish Financial Ombudsman (in financial matters) or to a municipal/district consumer ombudsman 12.2. Notice regarding the ODR platform: the European Online Dispute Resolution platform, previously available at ec.europa.eu/consumers/odr, was permanently shut down on 20 July 2025, pursuant to an EU legal act repealing Regulation (EU) No 524/2013 on online dispute resolution for consumer disputes. Up-to-date out-of-court dispute resolution pathways are available on the UOKiK website (below). 12.3. Detailed information on out-of-court consumer dispute resolution, including the list of entities authorised to conduct ADR proceedings, is available on the website of the Polish Office of Competition and Consumer Protection: https://uokik.gov.pl/pozasadowe-rozwiazywanie-sporow-konsumenckich. 12.4. The Service Provider does not undertake to participate in out-of-court consumer dispute resolution proceedings. The Service Provider's consent to participate in a specific ADR proceeding is granted on a case-by-case basis upon receipt of a request.

13.1. The Service Provider reserves the right to amend these Terms of Service for important reasons, such as: • Changes in legislation affecting the services provided • Changes in the scope or method of providing Electronic Services • The need to adapt the Terms of Service to orders, rulings, or decisions of administrative authorities 13.2. The Service Provider will inform Users of changes through: • Publication of the new Terms of Service on the Website • Posting information about the change on the Website for a period of at least 14 days • The full changelog of the Terms of Service, with dates and descriptions of modifications, is available at: epko.tech/en/terms/changelog 13.3. Changes take effect on the date specified in the change notice, no sooner than 14 days from the date of publication of the amended Terms of Service. 13.4. Using the Website after the changes take effect constitutes acceptance of those changes.

14.1. This version of the Terms of Service comes into effect on May 13, 2026 and replaces the version dated May 10, 2026. The changes reflect the shutdown of the European ODR platform, supplement the text and data mining clause (TDM opt-out under the DSM Directive 2019/790), clarify the notice-and-action mechanism under Articles 16-17 DSA, add an AI Act-compliant transparency declaration under Article 50 of Regulation (EU) 2024/1689, supplement the information required by Article 13 GDPR (data subject rights, right to lodge a complaint with the Polish DPA, right to withdraw consent), add a jurisdiction clause for EU consumers in line with the Brussels I bis Regulation, and introduce a language version priority clause favouring the Polish version. 14.2. These Terms of Service are available free of charge on the Website in a form that allows downloading, saving, and printing. 14.3. Matters not regulated by these Terms of Service shall be governed by Polish law and European Union law, in particular: • The Civil Code (Journal of Laws 2024, item 1061, as amended) • The Act on Electronic Service Provision (Journal of Laws 2020, item 344, as amended) • The Consumer Rights Act (Journal of Laws 2024, item 1796, as amended) • The Act on Copyright and Related Rights (Journal of Laws 2022, item 2509, as amended) • The GDPR Regulation (EU 2016/679) • Regulation (EU) 2022/2065 (Digital Services Act — DSA) • Directive (EU) 2019/882 (European Accessibility Act — EAA) and the Polish implementing legislation • Directive (EU) 2019/790 (DSM Directive — copyright in the digital single market), in particular Article 4 on text and data mining • Regulation (EU) 2024/1689 (Artificial Intelligence Act), in particular Article 50 on transparency obligations • Regulation (EU) No 1215/2012 (Brussels I bis — jurisdiction and the recognition and enforcement of judgments in civil and commercial matters) 14.4. If any provision of these Terms of Service is found to be invalid or ineffective, the remaining provisions shall remain in force. 14.5. Any disputes arising from the use of the Website shall be resolved by a court having jurisdiction under Polish law. For Consumers and sole traders with consumer rights domiciled in another Member State of the European Union, court jurisdiction is determined in accordance with Regulation (EU) No 1215/2012 (Brussels I bis), in particular: • a Consumer may bring proceedings against the Service Provider either in the courts of the Member State where the Consumer is domiciled or in the courts of the Member State where the Service Provider is established, • proceedings against a Consumer may be brought only in the courts of the Member State in which the Consumer is domiciled. This clause does not limit the rights of the Consumer arising from the mandatory provisions of the law of the Consumer's country of residence. 14.6. Language version of the Terms of Service: these Terms of Service are drawn up in both Polish and English. The Polish version is the original version and, in the event of any discrepancies between the Polish version and the English translation, the Polish version shall prevail. The above reservation does not limit the rights of Consumers or sole traders with consumer rights: in relations with such persons, the interpretation most favourable to them shall apply, and in case of doubt the provisions of these Terms of Service shall be interpreted in their favour (Article 385 § 2 second sentence of the Polish Civil Code).