Terms of Service

§ 1. Definitions

For the purposes of these Terms, the following expressions have the following meanings:

1. Account — the individual set of resources in the Service, identified by an email address, through which the User accesses the Services.
2. Account Holder — the person who concludes the Agreement and is bound by these Terms. The Account Holder is the User operating the Account; where that User is under the age of 18, they act with the permission of their Guardian, on the terms in § 7.
3. Agreement — the contract for the electronic provision of the Services, concluded between the Operator and the Account Holder on the terms set out herein.
4. Beta — the pre-stable stage of the Service's development, described in § 3 ust. 7.
5. Business User — an Account Holder who concludes the Agreement directly in connection with their business or professional activity, and for whom the Agreement is of a professional character.
6. Consumer — a natural person who concludes the Agreement for purposes not directly related to their business or professional activity, within the meaning of art. 22¹ of the Polish Civil Code.
7. Guardian — a parent or legal guardian of a User under the age of 18.
8. Operator — Mikhail Shabatura, a natural person conducting business activity registered in the Central Registration and Information on Business (CEIDG), with a registered address at Jana III Sobieskiego 11/21, 15-013 Białystok, Polska, NIP 9662192552, REGON 528667570.
9. Provider — a User who holds the provider role and who delivers Sessions to Recipients using the Service.
10. Recipient — a User who holds the recipient role and who participates in Sessions delivered by a Provider.
11. Session — a scheduled real-time audio-visual meeting conducted between one Provider and one Recipient by means of the Service.
12. Service — the software made available by the Operator under the name Relentu, comprising the functionalities listed in § 3.
13. Services — the services provided electronically by the Operator by means of the Service.
14. Subscription — a paid plan giving a Provider access to designated functionalities of the Service, on the terms set out in the Payment Policy.
15. Terms — this document, constituting the regulations referred to in art. 8 of the Polish Act of 18 July 2002 on the provision of services by electronic means.
16. User — a natural person who operates an Account, irrespective of age.
17. User Content — any data, text, files, notes, messages, images, or recordings introduced into the Service by a User.

Where these Terms refer to "you", the reference is to the Account Holder and, where the context requires, to the User operating the Account.

§ 2. General provisions

1. The Operator is: Mikhail Shabatura, Jana III Sobieskiego 11/21, 15-013 Białystok, Polska, NIP 9662192552, REGON 528667570.
2. Contact with the Operator is effected: a) in all general matters — at hello@relentu.com; b) in matters concerning these Terms, complaints, withdrawal from the Agreement, and notices under § 13 — at legal@relentu.com; c) by post — at the address indicated in ust. 1.
3. These Terms constitute the regulations within the meaning of art. 8 of the Act on the provision of services by electronic means, and are made available free of charge before the Agreement is concluded, in a manner enabling their acquisition, reproduction, and recording.
4. The Operator provides the Services within the territory of the European Economic Area and in such other territories as the Operator designates. The Operator applies no geographic restriction to registration or to use of the Services.
5. The Operator is a provider of hosting services within the meaning of art. 3(g)(iii) of Regulation (EU) 2022/2065 (Digital Services Act). The Operator does not disseminate User Content to the public and is not an online platform within the meaning of art. 3(i) of that Regulation.
6. The Operator does not intermediate in, facilitate, process, or take any part in payments between Providers and Recipients. Any financial relationship between a Provider and a Recipient arises outside the Service and the Operator is not a party to it.

§ 3. Type and scope of the Services

1. The Service is a software tool enabling a Provider to deliver Sessions to their own Recipients.
2. The Services comprise: creation and administration of an Account; scheduling and management of Sessions; conduct of Sessions by means of real-time audio-visual transmission; exchange of text messages, files, and voice messages; creation of notes, activity cards, and session recaps.
3. A Session is conducted between one Provider and one Recipient. The Service provides no group-session functionality.
4. The Operator provides the Services on a free basis, save for those functionalities reserved to a Subscription, which are made available to Providers on the terms set out in the Payment Policy.
5. The Operator is not, and does not hold itself out as: a school, university, or accredited educational institution; a provider of psychological, therapeutic, counselling, medical, or healthcare services; an emergency service; an employer, agent, principal, or representative of any Provider; a party to any legal relationship between a Provider and a Recipient.
6. The Operator does not verify, supervise, evaluate, endorse, or accept responsibility for the content, quality, legality, or suitability of any Session. The Provider alone determines the content, level, method, materials, and terms of each Session.
7. The Service is provided in Beta. In the Beta stage the Operator may add, modify, restrict, or withdraw any functionality of the Service. The Operator does not guarantee any level of availability, latency, or transmission quality, and does not provide a service-level agreement. This provision does not exclude or limit the rights of a Consumer arising under Chapter 5b of the Act on Consumer Rights, which cannot be excluded or limited by contract.
8. Sessions are not recorded by the Service. Recording by a participant, including a screen recording, requires the prior, express, and demonstrable consent of every other participant of the Session, and — where a participant is under the age of 18 — of that participant's Guardian.
9. The audio-visual transmission of a Session is encrypted between the participants' devices. Where the transmission is relayed through the Operator's infrastructure, the relay transmits encrypted packets and the Operator does not have access to its content. Text messages, files, voice messages, notes, activity cards, and session recaps are stored on the Operator's servers and are processed by the Operator for the purpose of providing the Services. The categories of data processed, the purposes, the legal bases, and the retention periods are set out in the Privacy Policy.
10. The Operator does not carry out general monitoring of the content of Sessions or of communications between Users, and is under no obligation to do so (art. 8 of Regulation (EU) 2022/2065). It follows that the Operator cannot observe what occurs during a Session. Content stored in accordance with ust. 9 is examined by a person acting for the Operator only where necessary to examine a notification or complaint submitted under § 13, to comply with a lawful request of a competent authority, or to protect the vital interests of a natural person.

§ 4. Technical requirements

1. Use of the Services requires: a device with access to the Internet; a current version of a web browser supporting WebRTC; an active email account; and, for participation in Sessions, a microphone and camera.
2. Audio-visual transmission during a Session is effected directly between the participants' devices. Where a direct connection cannot be established, the transmission is relayed through a relay server operated by the Operator; the relay does not decrypt the transmission. Transmission quality depends on factors outside the Operator's control, in particular on the parameters of the participants' Internet connections and devices.
3. The Account Holder is prohibited from supplying content of an unlawful character, in accordance with art. 8 ust. 3 pkt 2 lit. b of the Act on the provision of services by electronic means. The catalogue of prohibited conduct is set out in § 8 and in the Acceptable Use Policy.

§ 5. Conclusion and termination of the Agreement

1. The Agreement is concluded upon the Operator's confirmation of registration of the Account.
2. Registration requires the submission of the data indicated in the registration form and a declaration of acceptance of these Terms. That declaration also carries the confirmation referred to in § 7 ust. 1.
3. The Agreement is concluded for an indefinite period.
4. The Account Holder may terminate the Agreement at any time, without stating reasons and without incurring any charge, by deleting the Account in the Account settings or by notice sent to legal@relentu.com. Termination takes effect upon receipt.
5. The Operator may terminate the Agreement with fourteen (14) days' notice, or suspend access to the Account with immediate effect, where the Account Holder or the User: a) grossly or persistently breaches these Terms or the Acceptable Use Policy; b) uses the Service unlawfully, or for a purpose outside the scope described in § 3; c) creates a risk to the safety of another User, in particular a minor; d) has supplied false data concerning identity, age, or capacity; e) fails to remedy a breach within a reasonable period specified in the Operator's notice.
6. Where suspension is applied under ust. 5, the Operator shall inform the Account Holder of the grounds without undue delay and shall afford an opportunity to submit observations, unless prevented from doing so by law or by an overriding need to protect another User.
7. Where the Operator establishes that the confirmation referred to in § 7 ust. 1 was false, the Operator may terminate the Agreement with immediate effect.
8. Where the Agreement is terminated pursuant to ust. 5 on account of a material breach committed by a Business User, prepaid Subscription fees are not refunded for the unused period. This provision does not apply to a Consumer.
9. Where the Operator ceases to provide the Services, in whole or in a given territory, it shall give thirty (30) days' notice, save where immediate cessation is required by law or by an overriding safety consideration. Any prepaid and unused portion of a Subscription shall be refunded pro rata.
10. Termination of the Agreement does not affect: the ownership of User Content; the provisions of § 12, § 13 ust. 4, § 16, and § 17; and any obligation that by its nature is intended to survive.

§ 6. Account and roles

1. An Account is personal and may not be shared, transferred, or assigned. The Operator does not verify whether one natural person holds more than one Account.
2. Each Account bears exactly one of two roles, which cannot be combined on a single Account: a) Provider; b) Recipient.
3. The Provider role may be held only by a person who has attained the age of 18. A Subscription may be purchased only by a Provider.
4. The Recipient role may be held by a User of any age, subject to § 7.
5. The Account Holder is responsible for all activity conducted through the Account. The Account Holder shall protect the Account credentials and notify the Operator without undue delay at legal@relentu.com of any suspected unauthorised access. The Service does not offer two-factor authentication; should it be introduced, these Terms will say so.
6. A Provider represents and warrants that they hold every licence, qualification, registration, and authorisation required by the law of their jurisdiction, and of the jurisdiction of their Recipient, in order to deliver the Sessions they offer. The Operator does not verify such licences and their absence is a matter between the Provider and their Recipient.
7. A Provider who delivers Sessions to a person under the age of 18 shall comply with every obligation imposed on them by the law applicable to activity involving minors, including — where applicable to that Provider — the Polish Act of 13 May 2016 on counteracting the threat of sexual offences and on the protection of minors. The Operator does not perform, and is under no obligation to perform, any screening, register check, or vetting of Providers.

§ 7. Age, and Users under the age of 18

1. On registering an Account the Account Holder confirms that they have attained the age of 18, or that they use the Service with the permission of their Guardian, who accepts these Terms on their behalf and remains responsible for that use.
2. The Operator does not collect a date of birth and does not verify the age or the capacity of any User. The confirmation in ust. 1 is what the Operator relies on, and it is recorded together with the moment at which it was given.
3. The Service is addressed to adults. A User under the age of 18 uses it through their Guardian, or under a Provider's arrangement with that Guardian.
4. A Provider who accepts a person under the age of 18 as a Recipient is responsible for obtaining the consent of that person's Guardian, including any consent required for the processing of that person's personal data under art. 8 of Regulation (EU) 2016/679. The Operator neither obtains nor verifies that consent.
5. Where the confirmation referred to in ust. 1 was false, the Operator bears no responsibility for consequences that would not have arisen had accurate data been supplied, and may act in accordance with § 5 ust. 7. This provision does not limit the Operator's liability under § 12 ust. 4.

§ 8. Obligations of the parties

1. The Operator undertakes to provide the Services with due diligence, and to maintain technical and organisational measures appropriate to the risk, as described in the Privacy Policy.
2. The Account Holder and the User undertake to use the Services in accordance with these Terms, the Acceptable Use Policy, the law, and good morals, and in particular not to: a) harass, threaten, exploit, sexualise, groom, or endanger any person, in particular a minor; b) supply content of an unlawful character; c) infringe the intellectual property rights or personality rights of any person, including by distributing teaching materials they have no right to distribute; d) distribute malicious software, unsolicited commercial communications, or spam; e) circumvent rate limits, scrape the interface, or probe the Service for vulnerabilities otherwise than under a coordinated disclosure procedure invited by the Operator in writing; f) use the Service to provide psychological, therapeutic, medical, or emergency services; g) misrepresent identity, age, capacity, credentials, or affiliation; h) disclose outside a Session the identity, image, voice, or content of another participant without that participant's consent, or that of their Guardian.
3. The Service is not an emergency service. In an emergency, contact the competent emergency services.

§ 9. Subscription and payment

1. Designated functionalities of the Service are made available to Providers under a Subscription.
2. The terms of purchase, billing cadence, price, taxes, renewal, failed payment, cancellation, and refund are set out in the Payment Policy, which forms an integral part of these Terms.
3. Payments are processed by an external payment service provider indicated in the Sub-processors list. The Operator does not store payment card data.
4. The Service provides no mechanism by which a Provider may charge, invoice, or collect payment from a Recipient. Any remuneration owed to a Provider by a Recipient is agreed and settled entirely outside the Service.

§ 10. Right of withdrawal (Consumers)

1. A Consumer who has concluded a Subscription at a distance may withdraw from it within fourteen (14) days, without stating reasons and without incurring costs, save as provided in ust. 5.
2. The period runs from the day of conclusion of the Agreement for the Subscription. To meet the deadline it suffices to dispatch the declaration before its expiry.
3. The declaration may be submitted in any form, including by using the model form constituting Annex 1 to these Terms, sent to legal@relentu.com.
4. In accordance with art. 38 ust. 1 pkt 1 of the Act on Consumer Rights, the right of withdrawal does not subsist where the Operator has performed the digital service in full, provided that performance commenced with the Consumer's express prior consent and with the Consumer's acknowledgement that upon full performance the right of withdrawal is lost.
5. Where the Consumer requested that performance commence before expiry of the withdrawal period and subsequently withdraws, the Consumer pays an amount proportional to the performance rendered up to the moment of withdrawal (art. 35 of that Act). The Operator obtains that request expressly at checkout, before payment, and records it together with the moment at which it was given.
6. The Operator returns all payments received without undue delay and in any event within fourteen (14) days of receipt of the declaration, using the same means of payment.
7. This paragraph does not apply to a Business User.

§ 11. Complaints

1. Complaints concerning the Services may be submitted at any time to legal@relentu.com or by post to the address in § 2 ust. 1.
2. A complaint should indicate: the data identifying the Account Holder, a description of the objection, and the remedy sought. Failure to include any of these does not prevent the complaint from being examined.
3. The Operator examines the complaint and responds within fourteen (14) days of its receipt. In accordance with art. 7a of the Act on Consumer Rights, failure to respond to a Consumer's complaint within that period is deemed to constitute acceptance of the complaint.
4. The response is provided on a durable medium, to the email address associated with the Account.

§ 12. Liability

1. Towards a Consumer, the Operator bears liability on the general principles of the Polish Civil Code and of the Act on Consumer Rights. Nothing in these Terms excludes or limits that liability, and any provision that would do so is not binding on the Consumer.
2. Towards a Business User, the Operator's aggregate liability arising from or in connection with the Agreement, on any legal basis, is limited to the total of the Subscription fees paid by that Business User in the twelve (12) months preceding the event giving rise to the claim. Liability for lost profits towards a Business User is excluded.
3. The Operator is not liable for any act, omission, statement, decision, or content of a Provider or a Recipient, nor for the course, quality, or outcome of any Session. The Operator is not a party to the relationship between a Provider and a Recipient.
4. The limitations in ust. 2 and ust. 3 do not apply to, and the Operator's liability is never excluded or limited in respect of: a) damage caused intentionally (art. 473 § 2 of the Civil Code); b) harm to life or health; c) liability arising under Regulation (EU) 2016/679 or other data-protection law; d) rights that mandatory provisions of law reserve to a Consumer.
5. Neither party is liable for non-performance caused by force majeure, being an external event, unforeseeable, and impossible to prevent, including in particular natural disaster, armed conflict, act of public authority, or failure of a public telecommunications network. The affected party shall notify the other without undue delay.
6. In the Beta stage the Operator does not warrant the continued availability of stored User Content. The Operator shall afford the Account Holder a reasonable period to export User Content prior to any planned removal. This provision does not affect the rights referred to in ust. 1 and ust. 4.

§ 13. User Content, licence, and moderation

1. The Account Holder retains all rights in User Content.
2. The Account Holder grants the Operator a non-exclusive, worldwide, royalty-free licence to store, reproduce, transmit, display, and process User Content solely for the purpose of providing the Services to the User and to persons whom the User has authorised to access it. The licence expires upon deletion of the User Content or of the Account, save to the extent that further storage is required by law.
3. The Operator shall not: use User Content to train artificial-intelligence models, whether its own or those of any third party; sell or licence User Content to third parties; or display advertising selected on the basis of User Content.
4. All rights in the Service itself — the software, the interface, the trade marks, and the documentation — vest in the Operator. The Account Holder may not copy, resell, decompile, reverse-engineer, or rebrand the Service, save to the extent that such acts cannot be prohibited by law.
5. Notice and action. Any person may notify the Operator, at legal@relentu.com, of the presence of information which that person considers to be illegal content, in accordance with art. 16 of Regulation (EU) 2022/2065. The notification should permit the Operator to identify the content and to assess its character, and should state the reasons for the allegation and the location of the content.
6. The Operator confirms receipt of a notification without undue delay, examines it diligently and objectively, and informs the notifying person of its decision. A notification is not itself a finding: the Operator forms its own view, and the making of a notification establishes nothing against the Account Holder concerned.
7. Where the Operator restricts access to User Content, suspends an Account, or terminates the Agreement on the ground of illegal content or of a breach of § 8, it provides the Account Holder with a statement of reasons in accordance with art. 17 of that Regulation, together with information on the available means of redress. The ordinary course is that the Operator first states what it has found and allows a period in which to remedy it; measures are applied immediately where the safety of a minor is concerned.
8. The measures available to the Operator are limited to: restriction of visibility of the content concerned; removal of the content; suspension of the Account; and termination of the Agreement pursuant to § 5 ust. 5. The Operator applies them proportionately and having regard to the rights of all parties concerned.

§ 14. Personal data

1. The controller of personal data is the Operator.
2. The purposes, legal bases, retention periods, recipients, transfers, and the rights of data subjects are set out in the Privacy Policy. Cookies and similar technologies are described in the Cookie Policy. The vendors processing personal data on the Operator's behalf are listed in the Sub-processors document.
3. Where a Provider determines the purposes and means of processing personal data of their Recipients, that Provider is a separate controller and the Data Processing Agreement applies between the Provider and the Operator.
4. In the event of a personal data breach the Operator shall act in accordance with arts. 33 and 34 of Regulation (EU) 2016/679.

§ 15. Amendments to the Terms

1. The Operator may amend these Terms only for a valid reason, being: a) a change in generally applicable law, or in its official interpretation, affecting the Services; b) the issuance of a decision, recommendation, or ruling by a court or public authority affecting the Services; c) a change in the scope or manner of provision of the Services, including the introduction or withdrawal of a functionality; d) a change in the technical requirements set out in § 4; e) a change in the prices or terms of third-party services on which the Services depend; f) the need to counteract fraud, abuse, or a threat to the security of the Services; g) the correction of manifest errors or ambiguities, provided the amendment does not alter the parties' rights and obligations.
2. The Operator shall notify the Account Holder of an amendment, together with the valid reason relied on, at least fourteen (14) days before it takes effect, by a notice displayed within the Service. Until the amendment takes effect the notice may be set aside; from the day it takes effect it is displayed until the new version is accepted.
3. Where the Account Holder does not accept the amendment, they may terminate the Agreement with immediate effect before the amendment takes effect. In that case the amendment does not bind them, and any prepaid and unused portion of a Subscription is refunded pro rata.
4. An amendment relating solely to the correction of a typographical error, or to a change in the Operator's contact details, takes effect upon publication.
5. The version of these Terms in force, and the date on which it took effect, are displayed on this page, so that the Account Holder can always establish which text binds them.

§ 16. Governing law and disputes

1. These Terms and the Agreement are governed by the law of the Republic of Poland.
2. The choice of law in ust. 1 does not deprive a Consumer of the protection afforded to them by provisions that cannot be derogated from by agreement under the law of the country of their habitual residence (art. 6(2) of Regulation (EC) No 593/2008, Rome I). Those provisions apply according to where the Consumer lives, irrespective of the language in which they read these Terms.
3. Disputes with a Consumer are subject to the jurisdiction determined by generally applicable provisions of law. The Operator does not stipulate a court of its own seat.
4. Disputes with a Business User are subject to the jurisdiction of the court having jurisdiction over the Operator's registered address.
5. A Consumer may make use of out-of-court means of examining complaints and pursuing claims, in particular: a) mediation before a Provincial Inspector of Trade Inspection (Wojewódzki Inspektor Inspekcji Handlowej); b) a permanent consumer arbitration court operating at the Trade Inspection; c) assistance from a district (municipal) consumer ombudsman (Rzecznik Konsumentów) or a consumer organisation; d) the European Commission's Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr.
6. Recourse to the means referred to in ust. 5 is voluntary, and their availability does not restrict the right to bring proceedings before a court.
7. A Consumer may lodge a complaint concerning the processing of personal data with the President of the Personal Data Protection Office (Prezes UODO), ul. Stawki 2, 00-193 Warszawa.

§ 17. Final provisions

1. Should any provision of these Terms be held invalid or not binding on a Consumer, the remaining provisions remain in force (art. 385¹ § 2 of the Civil Code).
2. The Operator may assign its rights and obligations under the Agreement to a third party in connection with a transfer of the enterprise. The Operator shall notify the Account Holder, who may terminate the Agreement with immediate effect within fourteen (14) days of the notice.
3. Because the Operator conducts business as a natural person (JDG), the Operator bears personal liability under Polish law, within the limits set out in § 12. This provision does not extend the Operator's liability beyond those limits.
4. These Terms are published in Polish, English, Russian, and Hebrew. The Polish version is binding in relations with Consumers habitually resident in the Republic of Poland (Ustawa o języku polskim, art. 7–8). In relations with all other Account Holders the English version is binding. The Russian and Hebrew versions are provided for convenience and are not binding.
5. The following documents form an integral part of these Terms: the Payment Policy, the Acceptable Use Policy, the Privacy Policy, the Cookie Policy, the Sub-processors list, and — where § 14 ust. 3 applies — the Data Processing Agreement.

Annex 1 — Model withdrawal form

(Complete and return this form only if you wish to withdraw from the Agreement. Use of this form is not obligatory.)

Addressee: Mikhail Shabatura, Jana III Sobieskiego 11/21, 15-013 Białystok, Polska, legal@relentu.com

I/We (*) hereby give notice that I/We (*) withdraw from my/our (*) contract for the supply of the following digital service:

____________________________________________________

Date of conclusion of the contract: ________________________

Name of the consumer(s): ________________________

Address of the consumer(s): ________________________

Signature of the consumer(s) (only if this form is notified on paper): ________________

Date: ________________

(*) Delete as appropriate.

Mikhail Shabatura · Jana III Sobieskiego 11/21, 15-013 Białystok, Polska · NIP 9662192552 · REGON 528667570 General: hello@relentu.com · Legal: legal@relentu.com Effective as of 2026-08-01.