Simplora Progress Terms of Service

# Simplora Progress Terms of Service Effective date: 28 June 2026 Version: 1.0 Document identifier: 2026-06-28-en-v1.0 ## 1. Service provider and contact 1. Simplora Progress is provided by SIMPLORA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, with its registered address at ul. Gospodarcza 26, 20-213 Lublin, Poland, entered in the register of entrepreneurs of the National Court Register under KRS number 0001220863, NIP 9462763441, REGON 54385177200000, referred to in these Terms as "Simplora". 2. Simplora can be contacted by email at info@simplora.eu. 3. Simplora Progress is an electronically supplied SaaS service available at https://progress.simplora.eu or at another address indicated by Simplora. ## 2. Meaning of selected terms 1. "Terms" means this document. 2. "Service" or "Simplora Progress" means the web platform supporting speech progress monitoring, test and training task organization, and review of results over time. 3. "Organization" means an entity or solo professional practice through which a Specialist uses the Service. The Organization is the boundary for access to Patient Zones, subscriptions, and work data. 4. "Organization Administrator" means a Specialist account authorized to manage the Organization, billing, subscription, and Specialist accounts within the scope provided by the Service. 5. "Specialist" means a person using the Service for professional purposes, including a speech therapist, neurologopedist, therapist, or another person authorized by an Organization to work with a Patient. 6. "Patient" means the person whose Patient Zone, tasks, recordings, results, or work history are handled in the Service. 7. "Guardian" means a person accepting required consents and taking actions on behalf of or for the benefit of a minor Patient, in accordance with their authority to do so. 8. "Patient Zone" means a collaboration space concerning one Patient within one Organization. 9. "Test Task" means a task used to collect a repeatable speech sample and assess changes over time. 10. "Training Task" means a task intended for exercises and work between sessions with a Specialist. 11. "Plan" means a variant of access to the Service, including a free plan or a paid subscription plan, with assigned limits. 12. "User Content" means data, recordings, notes, texts, settings, tasks, results, and other materials entered, uploaded, or generated in connection with use of the Service. ## 3. Nature of the Service 1. Simplora Progress is a tool supporting speech progress monitoring and organization of a Specialist's work. 2. The Service is not a medical device, diagnostic system, tool for automated clinical decision-making, or substitute for professional assessment by a Specialist. 3. Results, indicators, trends, training recommendations, and analyses generated in the Service are supportive in nature. The Specialist is responsible for interpreting, verifying, and using them in professional work. 4. Simplora does not provide medical, therapeutic, diagnostic, or health advisory services to Patients through the Service. 5. The Service may use automatic speech recognition, phonetic analysis, AI models, or other algorithms. Such mechanisms may make mistakes, may have different accuracy for different people, languages, devices, and recording conditions, and require human oversight. ## 4. B2B scope and no consumer paid purchase in the MVP 1. Paid Simplora Progress plans in the current MVP are intended only for businesses, sole proprietors, professional practices, clinics, centers, institutions, and other entities using the Service in connection with business or professional activity. 2. In the MVP, Simplora does not offer paid consumer plans to natural persons acting solely privately and outside any business or professional activity. 3. A Patient or Guardian may use functions made available to them by an Organization or Specialist, but this does not make them a purchaser of a paid Plan unless Simplora provides a separate consumer purchase process. 4. A person creating a Specialist account confirms that they act professionally or with authorization from an Organization and have the right to use the Service in that capacity. ## 5. Technical requirements 1. Use of the Service requires a device with an up-to-date web browser, internet access, an active email address, and, for recording functions, a microphone and browser permission to use it. 2. Operation of recording functions may depend on the browser, operating system, device settings, microphone quality, and acoustic conditions. 3. The User is responsible for securing their device, browser, email account, and password. 4. Simplora may define additional technical limits for files, audio formats, tasks, Patient Zones, Specialists, and invitations in accordance with the active Plan. ## 6. Account and registration 1. Use of selected Service functions requires creating an account and verifying the email address. 2. An account is assigned to one email address and one account type: Patient or Specialist. 3. The User must provide true, current data that does not infringe third-party rights. 4. The User must not share the account with unauthorized persons, bypass safeguards, or use another person's account. 5. Simplora may refuse account creation, block registration, or temporarily limit functions if justified by security, abuse, breach of the Terms, data risk, or legal requirements. 6. A minor Patient's account may be used by the Guardian and the Patient in accordance with the process provided by the Service. The Guardian is responsible for ensuring that account use is consistent with the Patient's welfare and the scope of consents given. ## 7. Organizations, Specialists, and Administrators 1. A Specialist uses the Service within an Organization. A Specialist's individual professional practice may be a one-person Organization. 2. The Organization Administrator manages Organization settings, subscription, billing, and Specialist accounts within the scope made available in the Service. 3. Organization Administrator status alone does not automatically grant access to Patient data, recordings, notes, or Patient Zones. Access to Patient Zone data requires proper assignment as a Specialist or a separate audited process compliant with law. 4. The Organization is responsible for ensuring that Specialists have proper qualifications, authorization, and legal grounds to work with Patients and to process data entered into the Service. 5. The Organization is responsible for the accuracy of controller data, contact details, billing details, and information provided to Patients. ## 8. Patient Zone, invitations, and consents 1. A Patient Zone is created by an authorized Specialist within an Organization. 2. Recording and analysis of a Patient's speech require prior effective consent through the process made available by the Service. The Service follows this rule: consent first, recording second. 3. For a minor Patient, the consent process may require Guardian identity details and confirmation of the Guardian's authority to act for the Patient. 4. Withdrawal of consent blocks future recording and processing within the scope requiring consent. Withdrawal of consent does not always automatically delete data collected earlier if continued storage is permitted or required on another legal basis. 5. Erasure, restriction of processing, access to data, or any other formal data request is handled according to the relevant procedure, privacy policy, data processing agreement, and applicable law. 6. Patient or Specialist invitations are intended only for their addressee. They must not be forwarded to unauthorized persons or used contrary to the purpose of the invitation. ## 9. Data, GDPR roles, and processing on behalf of the Organization 1. For Patient Zone data, Patient data, recordings, tasks, results, notes, and other data entered by an Organization, the data controller is generally the Organization or another entity indicated in the Organization's current controller record. 2. To the extent Simplora processes Patient Zone data to provide the Service to the Organization, Simplora acts as a processor within the meaning of the GDPR, under a data processing agreement or equivalent provisions accepted by the Organization. 3. Simplora may be a separate data controller for its own account data, security data, billing data, contact data, data required by law, and data related to pursuing or defending claims. 4. Detailed information on personal data processing is provided in the privacy policy, consent documents, and, where applicable, the data processing agreement. 5. The Organization undertakes not to enter into the Service any data that it is not entitled to process or entrust to Simplora. ## 10. Recordings, speech analysis, and results 1. The Service may enable recording speech samples, uploading recordings, automatic speech analysis, generating results, and presenting trends. 2. Result quality depends on many factors, including recording quality, noise, device, task language, manner of speech, technical state of the Service, and limitations of automatic speech recognition models. 3. Results may be inaccurate, incomplete, or non-representative. They should not be used as the sole basis for a diagnosis, therapy, medical, educational, legal, or financial decision. 4. The Specialist should verify results before using them in work with a Patient, documentation, communication with family, or communication with other persons. 5. The User must not upload recordings of persons who are not covered by the relevant Patient Zone and required consent. ## 11. Task generator and AI functions 1. The Service may include functions supporting creation of Test Tasks or Training Tasks, including generation of sentences or exercise suggestions. 2. Automatically generated content is a draft suggestion. The Specialist is responsible for reviewing, adjusting, approving, and assigning it to a Patient. 3. The User should not enter unlawful content, unnecessary data, special category data, content infringing third-party rights, or information they are not entitled to process into prompts, preferences, or descriptive fields. 4. Simplora may apply limits, filters, abuse monitoring, and safety mechanisms related to AI functions. ## 12. Subscriptions, plans, and payments 1. Available Plans, limits, and prices are presented in the Service or in Simplora materials. Limits may include, in particular, the number of active Patient Zones, number of Specialists, number of pending invitations, and scope of functions. 2. The free Plan may have limited functions and limits. A paid Plan provides access in accordance with the terms of that Plan. 3. Payments may be handled by Stripe or another payment operator indicated in the purchase process. The payment operator may apply its own terms, security requirements, and transaction authorization procedures. 4. Prices may be shown as net or gross amounts in accordance with the information in the purchase process and applicable tax rules. The sales document is issued using the billing details provided by the Organization. 5. Purchase of a paid Plan may require billing payer details, including company details, NIP or another tax identifier, billing address, and invoice email. 6. If the Organization cancels a paid subscription, access to the paid Plan remains active until the end of the current paid billing period, unless the purchase process or an individual arrangement states otherwise. 7. After a paid Plan ends, the Organization may be moved to the free Plan or another available Plan. Patient Zones exceeding the active Plan's limit may be set to inactive or read-only mode in accordance with the Service rules. 8. Simplora may refuse a refund for the unused part of a billing period in B2B relationships, unless applicable law, a billing error, a failure attributable to Simplora, or a separate arrangement provides otherwise. 9. Non-payment, chargeback, rejected transaction, or breach of the payment operator's terms may result in limitation, suspension, or change of the Plan, after taking into account the Organization's legitimate interests and data security. ## 13. Inactive mode, retention, and erasure 1. A Patient Zone may become inactive, in particular, after a Plan downgrade, limit overage, Organization closure, access removal, withdrawal of required consent, or as a result of a retention process. 2. An inactive Patient Zone may remain available in read-only mode for a defined period if allowed by the Plan, retention settings, and applicable law. 3. In inactive mode, the ability to create new tasks, recordings, analyses, notes, or other changes may be blocked. 4. Subscription or payment status does not block formal data requests, such as data access, consent withdrawal, data erasure, or performance of legal obligations. 5. Retention periods, reminders, and data erasure may depend on the Plan, Patient Zone status, data category, legal obligations, and decisions of the Organization as data controller. ## 14. User obligations 1. The User agrees to use the Service in accordance with law, the Terms, good practices, security rules, and the purpose of the Service. 2. In particular, it is prohibited to: compromise Service security, bypass limits, attempt to access another person's data, test safeguards without Simplora's consent, upload malware, automatically overload the Service, infringe intellectual property rights, impersonate others, or enter data without the required legal basis. 3. The Specialist and Organization are responsible for tasks, notes, instructions, and information provided to the Patient through the Service. 4. The Patient and Guardian should perform tasks in accordance with the Specialist's instructions and should not use the Service where performing a task could threaten the Patient's safety, health, or wellbeing. ## 15. Intellectual property 1. Simplora, its marks, logos, interface, code, technical solutions, Service layout, documentation, and graphic elements are protected by law. 2. The User receives non-exclusive, non-transferable, limited access to the Service for the time and within the scope arising from the Terms, the Plan, and functions made available in the Service. 3. The Terms do not transfer any intellectual property rights in the Service to the User. 4. User Content remains owned by or under the control of the entity or person holding rights to it. The User grants Simplora the right to technically process User Content to the extent necessary to provide, secure, maintain, and develop the Service and perform legal obligations. ## 16. Availability, interruptions, and Service changes 1. Simplora uses due care to make the Service available in a stable and secure manner. 2. The Service may be temporarily unavailable due to maintenance, updates, failures, actions of external providers, random events, overload, security incidents, or other technical reasons. 3. Simplora may develop, change, add, or remove Service functions if this does not infringe essential acquired rights of the Organization under a paid Plan without a reasonable transition solution. 4. Simplora may make urgent changes without prior notice where necessary for security, legal compliance, data protection, or Service stability. ## 17. Suspension and termination of access 1. The User may stop using the account through functions available in the Service or by contacting Simplora. 2. The Organization may manage Specialist access within the scope provided in the Service. 3. Simplora may suspend, limit, or terminate access to an account, Organization, or selected functions if justified by breach of the Terms, security, data protection, abuse, non-payment, legal requirement, or risk of harm. 4. Where circumstances allow, Simplora will inform the relevant person or Organization of the reason for the limitation and possible remedial steps. 5. Termination of access does not release the User or Organization from paying amounts due, performing legal obligations, or complying with provisions that by their nature should survive termination of Service use. ## 18. Complaints and reports 1. Complaints concerning operation of the Service may be submitted to info@simplora.eu. 2. A complaint should include a description of the problem, date of occurrence, account or Organization details allowing the matter to be identified, and, where possible, screenshots or other technical information. 3. Simplora will respond to the complaint within a reasonable time, no later than within the period required by applicable law. 4. Reports concerning security, data breaches, or urgent access issues should be marked in the email subject in a way that helps identify the matter quickly. ## 19. Liability 1. Simplora is responsible for providing the Service in accordance with the Terms and applicable law. 2. To the extent permitted by law, Simplora is not liable for professional, clinical, therapeutic, organizational, or billing decisions made by an Organization, Specialist, Patient, or Guardian based on their own interpretation of data from the Service. 3. Simplora is not liable for content, instructions, notes, decisions, qualifications, actions, or omissions of Organizations, Specialists, Patients, or Guardians, unless Simplora's liability follows from mandatory provisions of law. 4. Simplora does not exclude or limit liability that cannot be excluded or limited under applicable law. 5. In B2B relationships, Simplora's liability for lost profits, indirect damages, and business interruption may be limited to the extent permitted by law and the relevant agreement with the Organization. ## 20. Changes to the Terms 1. Simplora may change the Terms, in particular, in the event of changes to the Service, Plans, prices, law, security requirements, operation of AI functions, technical providers, or data processing model. 2. A new version of the Terms receives a new document identifier and effective date. 3. If a change materially affects the rights or obligations of a User or Organization, Simplora will inform them with appropriate advance notice, unless earlier implementation is required by law, security, or an urgent technical need. 4. Continued use of the Service after the effective date of the new Terms may require acceptance of the new version. 5. A change to the Terms does not deprive the Organization of acquired rights for a paid billing period, unless the change is necessary for legal, security, or data protection reasons. ## 21. Governing law and disputes 1. The Terms are governed by Polish law, taking into account mandatory provisions of European Union law. 2. Disputes between Simplora and an Organization or Specialist using the Service professionally will be resolved by the competent common court in Poland, unless mandatory provisions of law state otherwise. 3. The provisions on governing law and court jurisdiction do not limit the rights of a Patient or another person where such rights cannot be limited under applicable law. ## 22. Final provisions 1. The Terms are made available in a way that allows them to be saved and reproduced. 2. If any provision of the Terms proves invalid or ineffective, the remaining provisions remain in force, and the invalid or ineffective provision should be replaced with a lawful solution closest to the purpose of the Terms. 3. Matters not regulated by the Terms are governed by applicable law and, where relevant, separate agreements concluded with the Organization, including the data processing agreement.