Refunds and complaints policy

REFUNDS AND COMPLAINTS POLICY

For business customers (B2B) — Border Force CRM service

Version: 1.1 · Effective from: 15 November 2026

This Policy implements the requirements of § 3 of the Paynow Service Terms (mElements S.A. / mBank S.A.) on complaints, refunds and payment reversals. The seller and service provider is Topolski, Stanley & Associates Sp. z o.o., registered office in Sopot, ul. Boh. Monte Cassino 39/14, 81-767 Sopot, Poland, entered in the National Court Register (KRS) kept by the District Court Gdańsk-Północ in Gdańsk, 7th Commercial Division, under KRS no. 0001009211, NIP (tax ID) 5851499597, REGON 523979996, share capital PLN 5,000.00, e-mail hello@topolskigroup.com, tel. +48 58 585 94 00 (the "Firm"). This Policy forms an integral part of the Terms of Cooperation — Border Force CRM (the "Terms"). The Polish version is binding; this English text is a translation.

1. Scope

1.1 The Border Force CRM service is provided exclusively to businesses (B2B) within the meaning of Article 43(1) of the Polish Civil Code that conclude the Agreement in direct connection with their business or professional activity.

1.2 As Customers are businesses, the statutory 14-day consumer right of withdrawal from distance contracts and other rights reserved for consumers do not apply.

1.3 Sole traders. Where the Customer is a natural person concluding the Agreement directly in connection with their business, and the Agreement does not have a professional character for that person (as shown in particular by the scope of business published in the Polish business register CEIDG), that person has the right of withdrawal under the Polish Consumer Rights Act of 30 May 2014 (Article 38a). Notice of withdrawal may be given within 14 days of conclusion of the Agreement to the e-mail or postal address in section 4.1. If such a person asked for the service to begin before the withdrawal period ended, they pay for the services provided up to withdrawal; the right of withdrawal is lost once the service has been fully performed with their express consent and acknowledgement of that loss. Sections 1.2 and 2.2 do not limit the rights of such a person.

1.4 Termination of the Agreement and subscriptions is governed by the Terms; this Policy governs refunds and complaints.

2. Free trial, termination of the Agreement and subscriptions

2.1 The free 14-day trial requires no payment and creates no payment obligation. When it ends, access expires automatically; the Firm charges nothing and issues no renewal order. Continued use requires choosing a package and paying the order. No refunds arise from the trial, as no payment is taken for it.

2.2 The Customer may cancel a subscription at any time with effect from the end of the current billing period, using the Customer Panel or by e-mail (clause 9.5 of the Terms). The fee for a billing period that has started is non-refundable and is not refunded pro rata (clause 9.6 of the Terms), subject to sections 1.3 and 3.1.

2.3 Additional services started before termination are settled in accordance with the Terms and the Order Confirmation.

3. Refunds

3.1 A refund is given only where it is due under the Agreement, in particular:

(a) where a paid service was not activated for reasons attributable to the Firm;

(b) following an upheld complaint;

(c) in the cases and on the terms of the Fee Refund Guarantee (Annex 8 to the Terms);

(d) on withdrawal by a person referred to in section 1.3;

(e) for an undue or duplicate payment.

3.2 Payments made through Paynow (mElements S.A.) are refunded through Paynow, using the same payment method the Customer used, unless the Customer agrees to another method at no cost to them. Payments made by ordinary bank transfer are refunded to the account from which they were received, unless the Customer names another account held in their name.

3.3 Refunds are made without undue delay from the day the refund is found to be due or the complaint is upheld. Where a person referred to in section 1.3 withdraws from the Agreement, the refund is made within the period set by the Polish Consumer Rights Act — no later than 14 days from receipt of the notice of withdrawal. The refund may be reduced by the fee due for services provided up to the date the refund became due. The date the funds reach the Customer depends on the payment operator and the Customer's bank.

3.4 Where an invoice was issued for the payment, the refund is documented with a corrective invoice issued in the Firm's accounting system.

4. Service complaints

4.1 Complaints about services provided by the Firm may be made:

(a) by e-mail to hello@topolskigroup.com;

(b) in writing to the complaints address: Topolski, Stanley & Associates Sp. z o.o., ul. Boh. Monte Cassino 39/14, 81-767 Sopot, Poland;

(c) by phone on +48 58 585 94 00 — the Firm then confirms receipt of the complaint by e-mail.

4.2 A complaint should include:

(a) the Customer's details and contact details;

(b) identification of the order or service (e.g. the ZAM order number or Order Confirmation number);

(c) a description of the issue;

(d) what the Customer is asking for.

4.3 The Firm deals with a complaint without undue delay and no later than 30 days from receipt and informs the Customer of the outcome by e-mail or in writing. If information needed to deal with the complaint is missing, the Firm asks for it; the period runs from receipt of the missing information.

5. Payment complaints

5.1 Complaints about the payment process (Paynow transactions) should be addressed to the payment operator, mElements S.A. (in cooperation with mBank S.A.). Terms and contact details: https://www.paynow.pl/regulaminy.

5.2 Payment complaints are handled by mElements S.A. under its complaints regulations — within 15 business days, or up to 35 business days in particularly complex cases.

5.3 Card payments are processed by Worldline Financial Services (Europe) S.A.; intermediaries are Visa, Mastercard and Autopay.

6. Governing law and jurisdiction

6.1 This Policy and the Agreement are governed by Polish law.

6.2 Disputes arising from the Agreement are resolved by the common courts in Gdańsk, except disputes with persons referred to in section 1.3, to which the general rules on jurisdiction apply.