Terms of Service — Sigil RMPD
Version: 1.4 Effective date: 29 May 2026 Last updated: 22 August 2026Definitions
For the purposes of these Terms, the following terms have the meanings set out below:
- "Sigil" — the operator of the Sigil RMPD platform, a software-as-a-service product.
- "Platform" — the Sigil RMPD web application, API, and all related software services.
- "Carrier" — the legal entity or individual entrepreneur (FOP) that has created an account on the Platform.
- "User" — any individual who accesses the Platform on behalf of the Carrier (owner, dispatcher, driver).
- "CMR" — a consignment note issued under the Convention on the Contract for the International Carriage of Goods by Road (CMR Convention).
- "SENT" — the Polish system for monitoring the transport of sensitive goods, operated by Krajowa Administracja Skarbowa (KAS).
- "PUESC" — the Polish Customs and Tax Services Electronic Portal operated by KAS.
- "RMPD100" — an electronic declaration of transport of sensitive goods submitted to SENT via PUESC.
- "Declaration Credit" — a prepaid unit of usage entitling the Carrier to submit one RMPD100 declaration electronically via SEAP to PUESC.
- "Credit Package" — a prepaid bundle of Declaration Credits purchased in a single transaction.
§1. Service Description
This document constitutes a public offer (публічна оферта) under Arts. 633, 641, 642 of the Civil Code of Ukraine.
Service Provider: FOP Makaiev Kostiantyn Oleksandrovych, RNOKPP 3142416974, Ukraine, 04136, Kyiv, 20V Ivan Vyhovsky St., Apt. 50. USR entry No. 2010350000000335583. Email: legal@sigil.app.Acceptance is effected by creating an account, ticking the acceptance checkbox, or completing a payment. The accepted Terms have the same legal force as a signed agreement between the parties. The Platform is intended solely for legal entities and individual entrepreneurs (FOP) for commercial purposes — not for personal or consumer use.
Sigil RMPD is a SaaS software tool that automates the preparation and electronic submission of RMPD100 declarations to the Polish PUESC/SENT system. The Platform uses OCR and AI technology to extract data from CMR documents and assists Users in completing the required fields.
Sigil is a technology product — not a customs agency, freight forwarder, customs representative, or legal intermediary of any kind.
§2. Tool Provider Clause — Core Commitment
Sigil is software. The Carrier is the declarant.Sigil provides technical means only. The Carrier remains the sole legal declarant for every SENT/RMPD100 notification submitted through the Platform. Sigil does not act and must not be construed to act as:
- a customs representative (*agencja celna*, *przedstawiciel celny*) within the meaning of Polish customs law;
- a holder of power of attorney (*pełnomocnik ogólny* or *pełnomocnik szczególny*) within the meaning of the Tax Ordinance Act;
- a legal agent or intermediary with PUESC/KAS;
- a co-signatory or co-declarant of any declaration.
This is not a limitation of liability clause — it is a description of the product's legal and technical architecture. Sigil connects to PUESC using the Carrier's own PUESC credentials, operating identically to any ERP or accounting software (e.g. Comarch, SAP) that transmits tax filings on behalf of a taxpayer using the taxpayer's own access token.
§3. Human Confirmation Requirement
Every PUESC submission made through the Platform requires explicit human confirmation. The User must:
1. Review each field extracted by OCR against the original CMR document;
2. Check the "I confirm data is transferred 1:1 from CMR" checkbox;
3. Actively press the Submit button.
No submission occurs without completion of all three steps. By pressing Submit, the User confirms that the declared data is accurate and accepts full legal responsibility for the content of the declaration. Sigil displays a reminder before each submission: *"You are filing this declaration as the legal declarant. Sigil is a technical tool only."*
§4. PUESC Credentials and Account Ownership
The Carrier creates, owns, and is solely responsible for their PUESC account and API credentials. Sigil stores the Carrier's PUESC credentials in encrypted form (AES-256-GCM at rest, TLS 1.3 in transit) and uses them solely to transmit declarations that the Carrier has reviewed and explicitly approved. Sigil does not create, manage, or hold PUESC accounts on behalf of Carriers.
The Carrier is responsible for: (a) the accuracy and validity of their PUESC credentials; (b) any PUESC account suspension or revocation; (c) any changes to PUESC access policies required by KAS.
4.1 Import of PUESC history. After the Carrier connects a PUESC account, Sigil can retrieve documents from that account's PUESC mailbox covering up to the last 12 months. This retrieval runs only on the Carrier's explicit instruction: it is started by the Carrier from within the Platform and is never triggered automatically. 4.2 Scope of the import. The import covers: RMPD declarations previously submitted from that PUESC account; tractor units and trailers together with their geolocator identifiers; the carrier entities the Carrier files declarations for; and the senders, recipients and delivery places recorded in those declarations. Imported data is placed in the Carrier's own account on the Platform and is not made available to other Carriers. 4.3 Retrieval in the Carrier's name. The import is performed with the Carrier's own PUESC credentials and in the Carrier's name. The Carrier remains the declarant and the owner of the data; Sigil acts solely as a technical tool (§2). 4.4 The PUESC inbox is shared and delivers each document once. The PUESC inbox hands each document over a single time, whichever system collects it — Sigil, other software connected to the same PUESC account, or the PUESC portal itself, where opening a response also marks it collected. A document collected by one of them is not delivered again to the others. This is a property of the PUESC service rather than of the Platform.The history import described in 4.1–4.3 is not affected by this: it retrieves documents by date range and does not consume them, which is why it can recover responses the inbox has already handed over.
§5. Account Registration and Access
5.1 Eligibility. The Platform is available to legally registered businesses and individual entrepreneurs (FOP) only. By creating an account, the Carrier represents that: (a) the Carrier is a legal entity or individual entrepreneur duly registered under applicable law; (b) the person completing registration is authorised to bind the Carrier; (c) the Carrier's transport activities require SENT/RMPD100 declarations under Polish law. 5.2 Account security. The Carrier is responsible for maintaining the confidentiality of login credentials and for all activity that occurs under their account. The Carrier must notify Sigil immediately at security@sigil.app upon becoming aware of any unauthorised access. 5.3 User roles. The Platform implements role-based access control (ADMIN, DISPATCHER, VIEWER). The Carrier is responsible for assigning appropriate roles and for the actions of all Users operating under the Carrier's account. 5.4 Account transfer. Accounts may not be transferred or sold without prior written consent from Sigil.§6. Declaration Credits, Payments and Refunds
6.1 Credit model. The Platform operates on a prepaid credit basis. 1 Declaration Credit = 1 RMPD100 declaration. Both electronic submission via SEAP and the first XML download of a given declaration consume 1 Declaration Credit. Re-downloading an XML for an RMPD that has already consumed a credit is free. Each new Carrier receives 10 free trial credits upon registering an account. Credits are non-transferable between separate Carrier accounts. 6.2 Credit packages and pricing. Sigil offers the following prepaid packages:| Package | Credits | Reference price (EUR) | Price per declaration |
| Single declaration | 1 | €3.00 | €3.00 |
| Pack 25 | 25 | €50.00 | €2.00 |
| Pack 50 | 50 | €95.00 | €1.90 |
| Pack 100 | 100 | €180.00 | €1.80 |
| Pack 200 | 200 | €340.00 | €1.70 |
| Pack 500 | 500 | €750.00 | €1.50 |
Prices above are shown in EUR for reference only. Payment is charged in UAH at the official NBU (National Bank of Ukraine) EUR/UAH exchange rate on the date of payment. The exact UAH amount is displayed on the payment confirmation screen before the Carrier authorises the transaction.
6.3 Payment processing. Payments are processed through LiqPay (operated by JSC CB PrivatBank, PCI DSS certified, 3D Secure). Available payment methods: Visa, Mastercard, Apple Pay, Google Pay, Privat24. Sigil does not store full card data; payment data is processed by LiqPay under their own privacy policy (liqpay.ua). Each purchase is a one-time payment — no automatic recurring charges are initiated. 6.4 Credit validity. Purchased credits do not expire. They remain in the Carrier's account until used. 6.5 Price changes. Sigil may update package prices at any time. Updated prices apply to new purchases only; credits already purchased remain valid. The Carrier will be notified of material price changes by email at least 30 days before they take effect. 6.6 Refunds. Purchased credits are non-refundable after a successful payment, except where required by applicable mandatory law. If a credit was incorrectly deducted due to a confirmed technical error by Sigil (not a user error or incorrect OCR data confirmed by the User), the credit will be restored. Disputes regarding payment amounts must be raised at legal@sigil.app within 30 days of purchase. 6.7 Platform access. Account registration and access to the Platform are free. Declaration Credits are required to submit a declaration (via SEAP or initial XML download). A zero credit balance does not suspend the account — the Carrier may continue to access previously submitted declarations and re-download XML files that have already consumed a credit. 6.8 Taxes. Prices shown are exclusive of any applicable taxes. The Carrier is responsible for all applicable taxes in their jurisdiction.§7. Acceptable Use
The Carrier and all Users must not:
(a) use the Platform for any unlawful purpose or in violation of any applicable regulation;
(b) submit declarations that they know to be false, inaccurate, or fraudulent;
(c) attempt to access the Platform or third-party systems (including PUESC) by automated means beyond the Platform's intended API;
(d) perform reverse engineering, decompilation, or disassembly of the Platform or its source code;
(e) resell, sublicense, or provide access to the Platform to third parties without Sigil's written consent;
(f) use the Platform in a manner that imposes an unreasonable or disproportionately large load on Sigil's infrastructure;
(g) introduce malware, viruses, or other harmful code.
Violation of these rules may result in immediate account suspension without refund.
§8. AI and OCR Limitations
Sigil uses AI/OCR technology to extract data from CMR images. This technology is an aid, not a substitute for human review. Extraction errors can and do occur, particularly with:
- low-resolution or blurred scans;
- handwritten or mixed-language fields;
- non-standard CMR document layouts.
The User is required to verify every extracted field against the original CMR document, regardless of any displayed confidence level or visual highlighting. Sigil bears no liability for SENT penalties, fines, or cargo seizure arising from errors in data that the User confirmed before submission.
§9. Service Availability
Sigil targets high availability but does not guarantee any specific uptime SLA. The Platform may be temporarily unavailable due to planned maintenance, emergency patches, infrastructure failures, or causes beyond Sigil's reasonable control. Sigil will endeavour to provide advance notice of planned maintenance via email or in-app notification where practicable.
§10. Intellectual Property
10.1 Platform. The Platform, including all software, design, trademarks, and documentation, is the exclusive intellectual property of Sigil. These Terms do not transfer any ownership of Platform IP to the Carrier. 10.2 Carrier data. The Carrier retains ownership of all data uploaded to or generated through the Platform (CMR documents, RMPD declarations, company data). Sigil is granted a limited, non-exclusive licence to process this data solely for the purpose of providing the Service. 10.3 Feedback. If the Carrier provides feedback or suggestions, Sigil may use them to improve the Platform without any obligation or compensation.§11. Confidentiality
Each party agrees to keep the other party's confidential information (including PUESC credentials, business data, pricing, and technical architecture) strictly confidential and not to disclose it to third parties except: (a) with the other party's prior written consent; (b) to employees or contractors who need access to perform obligations under these Terms and are bound by equivalent confidentiality obligations; (c) as required by law or regulatory authority.
§12. Data Processing
Sigil processes personal data in connection with the Service as described in the Privacy Policy (available at /legal/privacy) and, for corporate Carriers, the Data Processing Agreement (DPA, available at /legal/dpa). By accepting these Terms, the Carrier acknowledges that it has read and accepts the Privacy Policy and, where applicable, the DPA.
§13. Limitation of Liability
13.1 Cap. Sigil's maximum aggregate liability to the Carrier for all claims arising under or in connection with these Terms is limited to the total amounts paid by the Carrier for Declaration Credits in the three (3) months immediately preceding the event giving rise to the claim. 13.2 Exclusions. To the maximum extent permitted by applicable law, Sigil is not liable for:- customs, SENT, or KAS penalties, fines, or sanctions of any kind;
- cargo seizure, detention, or confiscation;
- indirect, consequential, incidental, special, or punitive damages;
- loss of profits, revenue, data, or business;
- damages arising from the Carrier's failure to verify OCR-extracted data before submission;
- damages arising from PUESC system unavailability or KAS policy changes.
13.3 Indemnification. The Carrier agrees to indemnify and hold harmless Sigil and its officers, employees, and contractors from and against any claims, damages, fines, or expenses (including reasonable legal fees) arising from: (a) the Carrier's breach of these Terms; (b) the Carrier's violation of applicable law; (c) any false or inaccurate declaration submitted through the Platform.§14. Term and Termination
14.1 Term. These Terms remain in effect for as long as the Carrier maintains an active account on the Platform. 14.2 Termination by Carrier. The Carrier may close their account at any time through the account settings. Any unused Declaration Credits at the time of account closure are forfeited and are not refunded, except where required by applicable mandatory law. 14.3 Termination by Sigil. Sigil may suspend or terminate the Carrier's account immediately if: (a) the Carrier breaches any provision of these Terms and fails to remedy the breach within 7 days of written notice; (b) the Carrier engages in fraudulent activity; (c) required by law or regulatory authority. 14.4 Effect of termination. Upon termination, the Carrier's access to the Platform ceases. Sigil will retain the Carrier's data for 30 days following termination, during which time the Carrier may request an export. After 30 days, data is deleted, subject to retention obligations required by law (see Privacy Policy §5).§15. Modifications to Terms
Sigil may modify these Terms at any time. The Carrier will be notified by email at least 30 days before material changes take effect. Continued use of the Platform after the effective date constitutes acceptance of the revised Terms. If the Carrier does not accept the changes, they may close their account before the effective date.
§16. Force Majeure
Neither party shall be liable for delays or failures in performance resulting from causes beyond their reasonable control, including: natural disasters, war, acts of terrorism, strikes, government actions, PUESC/KAS system outages, internet infrastructure failures, or pandemic.
§17. General Provisions
17.1 Severability. If any provision of these Terms is held invalid or unenforceable, the remaining provisions continue in full force and effect. 17.2 Waiver. Failure to enforce any provision of these Terms shall not constitute a waiver of the right to enforce it subsequently. 17.3 Entire agreement. These Terms, together with the Privacy Policy and DPA (where applicable), constitute the entire agreement between the parties regarding the Platform and supersede all prior representations or understandings. 17.4 Assignment. The Carrier may not assign rights or obligations under these Terms without Sigil's prior written consent. Sigil may assign these Terms in connection with a merger, acquisition, or sale of all or substantially all of its assets.§18. Governing Law and Disputes
These Terms are governed by the law of Ukraine (Civil Code of Ukraine, Arts. 633, 641, 642). Any dispute arising out of or in connection with these Terms shall be subject to the jurisdiction of the courts of Ukraine at the registered seat of Sigil. Carriers based outside Ukraine may agree to submit disputes to the International Commercial Arbitration Court at the Ukrainian Chamber of Commerce and Industry (ICAC at UCCI). The parties agree to attempt to resolve disputes amicably within 30 days before commencing formal proceedings.
*Questions regarding these Terms: legal@sigil.app*