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Early Access Programme Terms

Trim Alert AI Assistant · version 1.0 · August 2026 · translation of the Polish original, which is binding

§1. General provisions

  1. The organiser of the Early Access Programme (the "Programme") is TrimAlert sp. z o.o., with its registered office in Warsaw, ul. Przasnyska 7/319, 01-756 Warsaw, Poland, entered in the National Court Register (KRS) under number 0001233147, NIP 5253085087, REGON 544400468 (the "Organiser").
  2. The Programme concerns the Trim Alert AI Assistant tool (the "Tool") — a system supporting the analysis of AML alerts.
  3. These Terms set out the rules for participation in the Programme. Participation is free of charge and by invitation only.
  4. Only a professional entity may be a Participant — an obliged entity within the meaning of the Polish AML Act, or another business. The Programme is not addressed to consumers.
  5. The person registering represents that they are authorised to act on behalf of the Participant within the scope covered by these Terms.

§2. Nature of the Tool — key provisions

  1. The Tool is a tool supporting analysis, and not a law firm or an adviser. The Organiser does not provide legal or compliance advice.
  2. The risk assessment generated by the Tool is a recommendation, not a binding determination. Responsibility for the classification of risk and for decisions taken in respect of clients rests entirely with the Participant.
  3. The Tool does not discharge the Participant's statutory obligations under AML legislation. It does not replace an analyst, does not make notifications to the General Inspector of Financial Information (GIIF) and does not take decisions autonomously.
  4. Every result requires human verification before any regulatory or business use.
  5. Results are generated with the involvement of language models and may contain errors — including omissions, inaccuracies and results that are not reproducible on re-run. The Participant acknowledges this.
  6. The Tool uses public sources (registers, media). The Organiser does not warrant that they are complete, current or available.

§3. Scope of the Programme

  1. Only entities indicated by the Participant, information about which comes from public sources, are analysed under the Programme — in particular from the National Court Register, the Central Register of Beneficial Owners, the VAT taxpayers register and publicly available publications.
  2. The Participant does not transfer to the Organiser any data of its own clients, including data covered by banking secrecy or data originating from the Participant's own systems. An entity is indicated for analysis by providing its NIP number.
  3. The transfer of data referred to in paragraph 2 requires separate contractual arrangements. Until such arrangements are made, the Participant undertakes not to introduce such data.
  4. The functional scope made available under the Programme may be narrower than the target scope and is subject to change without notice.

§4. Rules of participation

  1. Participation requires an invitation issued by the Organiser. The number of places is limited.
  2. An account is personal and assigned to a single natural person. Sharing login credentials is prohibited.
  3. The Participant is responsible for the actions of persons using its accounts.
  4. The Organiser may refuse an invitation without giving reasons.

§5. No warranty and no SLA

  1. The Tool is made available "as is / as available".
  2. The Programme includes no warranty of availability or response time. The Organiser does not guarantee continuity of operation and may interrupt it at any time, including without notice.
  3. The Organiser does not warrant that use of the Tool will ensure the Participant's compliance with any regulatory requirement.

§6. Personal data

  1. In respect of the data of persons representing the Participant and using the Tool, the Organiser is the controller; details are set out in the privacy information notice provided together with these Terms.
  2. In respect of the data of persons whose information comes from public sources and is processed in the course of analysing entities indicated by the Participant, the Participant is the controller and the Organiser acts as a processor — solely on the Participant's documented instructions.
  3. The information obligation towards the persons referred to in paragraph 2 rests with the Participant as controller.
  4. The Programme is a test environment. The Participant should download reports on an ongoing basis — analysis results may be deleted at any time, including without notice.
  5. Copies serve the purpose of evaluating the Tool. Results obtained under the Programme do not constitute documentation of the financial security measures applied and are not included in the documentation kept by the Participant under AML legislation — in line with §2(3) and §10(1).
  6. The Organiser makes no commitment to retain results for any period, nor to make them available after the Participant's participation ends, and does not keep documentation for the purposes of the Participant's statutory obligations.

§7. Use of artificial intelligence — transparency information

  1. The Tool uses language models provided by Microsoft in the Azure OpenAI service for: the analysis of register data, the searching and classification of media information, and the generation of narrative justification.
  2. Division of work between code and model. The rules for composing the result — weights, thresholds, caps and overrides — are set out in the algorithm. The partial assessments of individual agents are proposed by the model, and the code imposes deterministic constraints on them.
  3. Human oversight. The Tool does not take decisions autonomously: it does not close cases, does not make notifications to authorities and does not change the status of a case without the user's involvement. Every recommendation requires the acceptance of an analyst, who may reject or correct it at any stage.
  4. Accuracy. Results are probabilistic in nature and may contain errors, including omissions. Re-running an analysis on the same data may produce a different result.
  5. Constraints imposed on the model. The Tool applies two layers of constraints, deliberately kept separate:
    • prohibitions written into the model's instructions — including a prohibition on supplying data that is not in the source, and a prohibition on recording full personal identification numbers;
    • deterministic corrections applied after the model's response — the code imposes hard limits on the partial assessment, zeroes an agent's contribution where no findings are made, limits the aggregate effect of mitigating factors, and reconciles the result with the itemised score where the two diverge. The Organiser distinguishes between the two: the first layer is an instruction which the model follows with high but not complete reliability; the second is executed by the code independently of the model's response.
  6. The response structure is enforced. The model replies in a fixed data format rather than free text; content outside that format does not reach the result.
  7. Protection against prompt injection. Content originating from external sources and from the user is filtered before being passed to the model, and attempts at manipulation are flagged in the result.
  8. Content labelling. Materials generated with the involvement of the model are labelled as AI-generated and as requiring verification.
  9. Data passed to the model. Data from public sources is passed to the Azure OpenAI service, including the given names, surnames and the six-digit prefix of the PESEL number of persons appearing in the registers, together with excerpts from media publications.
  10. Data is not used to train models. Under the terms of the Azure OpenAI service provider, prompts, responses and embeddings transmitted by the Organiser are not made available to OpenAI or to other model providers, are not used to improve their models or services, and are not used to train, retrain or improve the base models.
  11. Place of processing. Data under the Programme is processed within the European Economic Area.

§8. Confidentiality

  1. The parties undertake to keep confidential the information obtained in connection with the Programme, in particular information concerning the operation of the Tool, its results and the Participant's comments.
  2. This obligation lasts for three years after participation ends.
  3. The Organiser may refer to the fact of the Participant's participation in the Programme in its communications only with the Participant's prior consent.

§9. Liability

  1. The Programme is free of charge, and the Tool is made available for demonstration and testing purposes.
  2. The Organiser's liability for indirect damage, lost profits, decisions taken on the basis of the Tool's results and regulatory consequences on the Participant's side is excluded.
  3. The exclusions do not apply to damage caused intentionally.

§10. Prohibited conduct

The Participant is prohibited in particular from:

  1. using the results as the sole basis for a decision concerning a client;
  2. presenting the results as the Organiser's position before supervisory authorities;
  3. introducing into the Tool the data referred to in §3(2);
  4. reverse-engineering the code, circumventing limits, or automated retrieval of data outside the interface provided;
  5. making access available to third parties.

§11. Duration and termination

  1. The Programme runs until further notice.
  2. The Organiser may at any time and without giving reasons terminate the Programme or withdraw access from an individual Participant.
  3. The Participant may withdraw at any time by notifying the Organiser.
  4. The end of participation gives rise to no claims on either side.

§12. Amendments to the Terms

  1. The Organiser may amend these Terms, notifying Participants at the e-mail address assigned to the account.
  2. Continued use after seven days from the notification constitutes acceptance of the amendments. Non-acceptance means the end of participation.

§13. Governing law and disputes

  1. These Terms are governed by Polish law.
  2. The Polish version is binding.
  3. The parties submit disputes to negotiation for 30 days and, if unsuccessful, to the court having jurisdiction over the Organiser's registered office.