Website regulations

  1. General provisions
  2. §1 Definitions
    1. Service – service ( – an online service located at maintained by the Operator.
    2. Operator – SUPER GRUPA PL Sp. z o.o., KRS (National Court Register no.) 0000694486, NIP (tax ID no.): 9571075102, REGON (statistical no.) : 22216567.
    3. Regulations (Regulations of – this document defining regulations of
    4. User – a person with full legal capacity or a legal person or organisational unit without legal personality for whom/which a User Account was created as a result of the Registration process..
    5. Registration – the whole process ending in opening a User Account at topFX. All mandatory fields must be completed correctly.
    6. User account – account created for the User after the Registration process. The User Account is characterized by a unique login. Access to the User Account is possible through the Transaction Panel, only on the basis of the password set by the User and selected digits of his telephone number.
    7. Transaction Panel - a graphical interface that allows the User to manage the User Account at and to place currency exchange orders.
    8. Currencies – currencies that the Service allows to buy or sell. The list of supported currencies is available on the in the 'Exchange rates' tab.
    9. Notifications from –messages sent by the Website to the User using electronic communication channels, including in particular e-mail and text messaging services.
    10. Business Hours – time of availability of the services provided by the Website. Business Hours are published at in 'Contact' tab.
    11. Manual– manual for handling transactions in the Trading Panel of available in an electronic form at
    12. Act on electronic services – Act on the provision of electronic services (Act of 18 July 2002, Journal of Laws No. 144 item 1204, as amended).
    13. Foreign Exchange Law – Foreign Exchange Law Act (Act of 27 July 2002, Journal of Laws of 2007, No. 61, item 410, as amended).
    14. Act on money laundering – Act on counteracting the introduction to the financial circulation of financial assets originating from illegal or undisclosed sources and counteracting financing terrorism (Act of 16 November 2000, Journal of Laws of 2003, No. 153, item 1505, as amended).
    15. Act on personal data protection – Act on personal data protection (Act of 29 August 1997, Journal of Laws of 2002, No. 101, item 926, as amended).
    16. Regulation on e-invoices – Regulation of the Minister of Finance concerning the issuing and sending of invoices in electronic form and storing the invoices and making them available to tax authorities or tax control authorities (Regulation of 17 December 2010, Journal of Laws No. 249, item 1661, as amended).
    §2 Electronic service
    1. In accordance with the requirements of the Act on electronic services, the Operator shall establish the following Regulations.
    2. Every user has access to the Regulations. The Regulations are available under the “Regulations" tab at
    3. The Regulations set the rights and obligations of the Website Users and the Operator.
    4. The Operator provides the User with services available on the Website upon the terms and conditions set forth in the Regulations
    5. The Operator concludes an agreement with the User for the provision of electronic services upon the correct completion of the Registration. Registration can be completed only after the User has read and accepted the Regulations.
    6. The Regulations is a document adopted by the Management Board of the Operator.
  3. Services
  4. §3 Services
    1. The Operator operates the Website and provides services available on the Website, maintaining the highest commercial and security standards.
    2. The operator through the Website provides currency exchange services in the field of Supported Currencies. The exchange takes place using bank accounts maintained in appropriate currencies belonging to the Users and the Operator. The User submits all instructions regarding exchange of currency using the Transaction Panel.
    3. The currency exchange services provided by the Website are available to Users only during business hours. Any amendment of the Business Hours shall not be considered an amendment of these Regulations.
    §4 Registration
    1. In order to register on the Website, the User must correctly fill in the registration form available through a link from website, read and accept the Regulations.
    2. The extent of the data and steps required to complete the Registration process shall be indicated in the registration form.
    3. Provision of correct and accurate personal data or information identifying the legal person as well as the data on account numbers and the account currencies shall be required for the performance of a currency exchange transaction. Lack of possibility to perform a transaction resulting from an error or inaccuracy of provided data as well as failure to update such data shall not constitute a basis for any claims against the Operator.
    4. If the User provides incorrect or inaccurate data in the Registration process, the funds received shall be returned to the sender. In such an event, the amount returned shall be charged with a handling fee of PLN 20 and shall be netted with any bank costs arising from the transaction performed. Such costs depend on the Table of Fees and Commissions of the specific bank.
    5. The Website shall collect and process User personal data in accordance with the applicable laws and the Privacy Policy provided for in §18.
    §5 Deposit of funds
    1. In order to perform a currency exchange transaction (purchase or sales), the User must deposit funds to be exchanged to the Operator’s bank account.
    2. The User shall pay the funds to the bank account indicated by the Operator. The Operator, adequately to the transaction type and currency, shall indicate the Operator’s bank account for incoming payments under the 'Load an account' tab in the Transaction Panel.
    3. The Operator indicates the title for the transfer of funds.
    4. Indication of the Operator’s bank account for payments incoming from the User shall be performed in consideration of cost and transaction time optimisation.
    5. The User who makes foreign currency transfers should make them in the SHA option, i.e. sharing transfer costs between the User and the Operator.
    6. In the event the User fails to comply with the requirements set forth in item 5, all the fees paid by the Operator for the acceptance of a foreign currency transfer shall be charged against the User Account.
    7. The Operator shall not be held liable for the payments of funds to a bank account other than indicated by the Operator with a transfer title other than indicated by the Operator.
    8. Instructions on the performance of transactions, i.e. adding funds to the User Account, shall be provided online in the manual at
    §6 Currency exchange
    1. Exchange rates at which the User may make a foreign currency exchange transaction at a specific time shall be available in the Transaction Panel under the 'currency exchange' tab.
    2. Exchange of currency on the Website is possible after defining correctly in the Transaction Panel at least two bank accounts belonging to the User.
    3. At least one bank account must be denominated in PLN while the others must be kept in currencies listed as Supported Currencies, i.e. EUR, CHF, USD or GBP.
    4. Bank accounts must be held by a bank or a bank branch that has its registered office in the territory of the Republic of Poland.
    5. Withdrawal of funds in PLN or in foreign currencies following the exchange may be performed only to the accounts defined in the Transaction Panel.
    6. The Operator shall reserve the right to introduce minimum transaction amounts required for currency exchange transactions. An amendment to the minimum transaction value in specific currencies shall not constitute an amendment of the Regulations.
    7. The Operator shall accept a currency exchange transaction ordered by the User for execution when the transaction parameters are specified in the 'currency exchange form in Transacion Panel:
      1. transaction direction (buy, sell)
      2. currency
      3. bank account number for payment
      4. amount
      5. and accept by selecting the “Submit" option.
    8. The currency exchange is settled with the exchange rate published in the 'currency exchange' form in the Transaction Panel at the time the User accepts the transaction.
    §7 Withdrawal of funds
    1. After the currency exchange, the User withdraws the funds through the appropriate tab to the previously defined bank account.
    2. Withdrawal of PLN or exchanged currencies may only take place on bank accounts defined in the Transaction Panel.
    3. The User may request withdrawal of funds at any time, i.e during or after working hours
    4. Withdrawal of funds by the Service to the bank account indicated by the User, regardless of the transaction mode, is carried out during business hours.
    5. The User may withdraw funds without currency exchange under the provisions of points 6 and 7.
    6. The user who deposited funds at topFX and did not exchange them, may withdraw funds only to the bank account from which they were paid to the Service.
    7. The withdrawal of funds that were not exchanged on the Website to an account other than the one from which they were paid to the Website will be canceled. Repeating such withdrawal three times will result in charging a fee of PLN 50.
    8. If due to the withdrawal of funds to a bank account, the Operator bears the cost in the bank, the cost is charged to the User. The User is informed about the amount of the withdrawal cost in the appropriate tab of the Transaction Panel.
    9. The Operator introduces the minimum amounts of withdrawal of funds from the Website to bank accounts in the amount of PLN 50, EUR 5, CHF 5, USD 5, GBP 5. Payments of lower amounts are charged with additional cost, over the cost specified in point 8, in the amount of PLN 1 or the equivalent in the currency paid out. A change of minimum withdrawa value does not constitute a change to the Regulations.
    §8 Notifications from
    1. In order to ensure swift and secure currency exchange, the Website shall send e-mail messages or text messages to the User’s e-mail address or mobile phone indicated during Registration.
    2. Notifications from in the form of e-mail messages regarding the transaction process, including a one-time code for transaction authentication on the Website are sent to the User in the following circumstances:
      1. upon approval and completion of Registration,
      2. after funds are posted on the User Account (after the Operator’s bank account is credited with a transfer of funds for exchange from the User),
      3. after the Operator makes a transfer of the exchanged funds (after the Operator’s bank account is debited with a transfer of the exchanged funds to the User).
    3. Notifications from in the form of e-mails or text messages are sent to the User in the following circumstances:
      1. when defining bank accounts in the Transaction Panel
      2. when changing the password in the Transaction Panel or the Password Reset form,,
      3. when changing User data in the Transaction Panel.
    §9 Security
    1. The Operator does not send the access password to the Transaction Panel in a text message or to the User’s e-mail address.
    2. Operator nie wysyła poprzez SMS lub na adres email Użytkownika próśb o podanie jakichkolwiek danych, w szczególności hasła dostępu do Panelu Transakcyjnego.
    3. During Registration and from the moment the User logs into the Transaction Panel, any data sent between the Transaction Panel of the Website at and the User uses secure data transmission encrypted with a 256-bit key.
    4. In order to authenticate certain operations on the Website, the Operator uses a one-time code sent via e-mail or a text message and the access password.
    §10 Transaction settlement time
    1. Currency exchange transaction execution time shall be calculated from the moment the Operator’s bank accounts are credited with funds transferred by the User. In the event that funds are received on a business day after Business Hours, the time of receipt shall be the beginning of the Business Hours on the following business day.
    2. Currency exchange transaction execution times depend on the bank in which the User has their bank account that will be credited following the currency exchange transaction. The estimated time of transaction execution depends on the type of transaction, and participation of specific banks in the transaction are provided on
    3. The Operator is not responsible for delays caused by reasons beyond his control, in particular due to delays in the execution of bank transfers, telecommunications connection failures, causes attributable to the User, etc.
    §11 Accounting Documents
    1. After the execution of every transaction, the Operator shall issue a sales receipt to the User in the form of a receipt or invoice.
    2. Documentation of currency exchange and other transaction costs (e.g. bank costs) shall be available in an electronic form in the Transaction Panel.
    3. The User may refuse to agree to accounting documents to be issued in electronic form. In such a situation, the User shall be obliged to submit a relevant statement in writing and send it to the Operator’s registered address. The User shall bear lump sum costs or mail delivery at PLN 10 for the issuance and delivery of every accounting document in hard copy. The fee shall be payable upon receipt of cash on delivery.
    §12User data
    1. By using the Transaction Panel, the User has the possibility to verify and modify the data provided during the Registration.
    2. The user can change the address and telephone number.
    3. The User can not change the User's identifying information.
    §13 Fees
    1. The Operator shall not charge one-time or subscription fees for the creation and use of the User Account.
    2. The Operator shall charge fees to the User in the event that bank costs occur for the crediting or debiting of the Operator’s bank account. The User shall be notified every time they make an operation of adding or withdrawal of money with the amount of costs that shall be charged by the Operator.
    3. The User should make a foreign currency transfer from his account to the Operator’s account in the SHA option, i.e. where transfer costs are shared: the User bears the costs of the originator bank and the Operator bears the cost of the receiving bank.
    4. The Operator will make a foreign currency transfer to the User’s account with the SHA option. The costs of the foreign currency transfer on the Operator’s side are charged to the User. The amount of the cost is indicated during the currency exchange operation.
    5. In the event of a bank fee for the Operator receiving a transfer without maintaining the provisions of point 3 or described in §15 point 4, the costs of such operation shall be entirely covered by the User. If there are insufficient funds on the User Account to pay for such costs, the Operator shall request the User to reimburse the costs incurred and the User shall reimburse such costs to the Operator within three business days.
    §14 Technical requirements
    The technical requirements necessary for operating the Service are as follows:
    1. a computer or other device equipped with an operating system with access to the Internet,,
    2. an Internet browser supporting SSL encrypted connections,
    3. an e-mail account as well as an application for operating the e-mail account,
    4. a mobile phone,
    5. an application for reading PDF files.
  5. Limitations, reservations, incorrect transactions
  6. §15 Limitations in currency exchange transactions resulting from legal provisions
    1. The Operator shall reserve the right to suspend or refuse to perform a transaction without the need to justify if this arises from the provisions of the Act on money laundering or violation of other laws. In such an event, the User shall have no right to claims on that account.
    2. The Operator, in connection with the implemented anti-money laundering procedures, may request the User to provide additional explanations, information or data identifying the User, subject to the circumstances of point 1.
    3. If the User is not a party to the transaction, i.e. if the User is not the owner of the bank account defined in the Trading Panel to which the exchanged funds shall be transferred, then the Website User shall be obliged to tick the field “Third persons are party to the transaction" when defining the account and provide correct data of such a person or entity.
    4. When a party other than the User takes part in a currency exchange transaction and correct data of such party are not provided, the provisions of §12(5) shall apply.
    §16 Reservations
    1. If the User acts in breach of the Regulations or in any way acts to the detriment of the Operator or the Website, the Operator has the right to suspend, block or terminate the User's Account.
    2. In the event of loss or disclosure of the password to a third party by the User, the Operator is not responsible for any losses resulting from this fact.
    3. The Operator has the right to refuse or terminate the transaction in the following cases of the User's fault:
      1. During the Registration, the User provided false data,
      2. The User has added bank account numbers to the User Account that do not belong to him and did not indicate that the third party is their owner,
      3. The user has not updated the data necessary to correctly carry out the transaction,
      4. The user deliberately acts to the disadvantage of the Operator.
    4. The Operator has the right to refuse or terminate the transaction in the following cases not caused by the User:
      1. if there is a reasonable suspicion that in the transaction process without the Operator's knowledge and acceptance (eg by means of a hacker attack) the introduced or changed factor affecting the current exchange rate or other relevant facts affecting the transaction,
      2. resulting from the so-called force majeure, which the Operator could not foresee and counteract,
      3. due to the failure of electronic banking systems that mediate transactions,
      4. as a result of IT system failures at entities that provide hosting services or currency quotations for the Operator,
      5. in the event of situations preventing automatic data processing resulting from unauthorized alteration, damage, destruction or deletion of the Website's IT files.
    5. The Operator is not responsible for non-performance or improper performance of obligations under the Regulations, if it was caused by the circumstances of the so-called force majeure and for which the Operator had no influence despite due diligence. In the event of force majeure, the performance of the services will be suspended until the circumstances and consequences of force majeure cease to exist.
    6. The Operator is not responsible for any losses incurred by the User as a result of errors committed by the User, in particular:
      1. sending funds to an account other than indicated by the Operator,
      2. sending funds to the Operator's account with a transfer title other than that indicated by the Operator,
      3. entering an incorrect recipient's bank account number to transfer funds from the Operator,
      4. entering an incorrect currency in which the recipient's account is kept for transferring funds from the Operator,
      5. actions performed on the User's Account by unauthorized persons, if such a situation occurred due to the User's fault.
    §17 Incorrect transactions
    1. If, due to a human error or technical factors, the User has performed a currency exchange operation based on unrealistic, significantly different exchange rates, then such transaction will be canceled and the funds resulting from the execution of the transaction in nominal amount will be returned to the Operator.
    2. If due to human error or technical factors, the Operator transferred to the User's bank account an amount other than that resulting from a correctly conducted transaction on the Website, then:
      1. The User shall be obliged to return the surplus funds from the incorrect transaction to the Operator by the following business day from the day the Operator sends the request to return the surplus funds to the User’s e-mail address,
      2. The Operator is obliged to pay the User underpayment from an incorrect transaction, by the next business after receiving the client's complaint . The user submits a complaint using the contact form in the Transaction Panel with his reservations.
  7. Privacy policy and property rights
  8. §18 Users' privacy policy
    1. The personal data obtained using the Website in relation to the services provided with the Website is processed in accordance with the Act on personal data protection.
    2. In order to ensure proper and lawful protection of the personal data of Users, the Operator has established a personal data file registered with GIODO, in accordance with the guidelines of the Inspector General for Personal Data Protection (GIODO).
    3. The personal data controller in the meaning of the Act on personal data protection shall be the Operator.
    4. Acceptance of the Regulations shall also be considered the User’s consent for the processing of their personal data.
    5. Provision of personal data and consent to their processing shall be voluntary. Failure to consent to the processing of the data to the extent necessary for User Registration excludes the use of the Website.
    6. Consent for personal data processing for purposes of sending marketing information by the Operator and its related entities is optional and its lack does not exclude the use of the Website.
    7. The User shall be able to modify or delete their personal data from the personal data file kept by the Operator at any time. Deletion of such data shall automatically result in the User Account being blocked.
    8. Data provided by the User shall be used for the following purposes:
      1. correct, secure and lawful provision of services provided by the Operator using the Website,
      2. performing obligations arising from the provisions of the Act on money laundering,
      3. accounting purposes,
      4. informing Users of services offered by the Operator,
      5. necessary communication between the User and the Operator.
    9. The Operator does not provide User's personal data to other Users or other persons or economic entities without the User's consent.
    10. Identification of the IP address in the Transaction Panel is only used to ensure the security of the User and is not used for any statistical purposes.
    11. For the processing of personal data to the extent not provided for in these Regulations, the provisions of the Act on personal data protection together with its secondary legislation shall apply.
    12. The use of the Website means acceptance of the Privacy Policy.
    §19 Intellectual property rights
    1. The use of the materials provided in the portal shall be allowed solely to the extent of fair use in the meaning of copyright laws. Removal of materials obtained from the Website pages of any information on intellectual property rights or other information related to the restricted character of such materials shall constitute a breach of the law. Without being authorised to do so in writing by the Operator, the User may not distribute, send, modify, publish elsewhere or use the content of the Website pages for public or commercial purposes.
    2. The content of the Website pages is the property of the Operator. The logo and the names presented on the Website pages are trademarks or works owned by the Operator. All trademarks and materials that can be displayed or read on the Website pages are protected by the law and may not be used without prior written consent of the Operator. Any economic and moral copyrights in the Website and in any of its elements shall be reserved.
  9. Final Provisions
  10. §20 Complaints
    1. The User has the right to submit a complaint if – in the User’s opinion, the Website services are performed in breach of the Regulations.
    2. Complaints should be reported immediately after the occurrence of the circumstances being the reason for the complaint.
    3. The user submits a complaint using the contact form available from the Transaction Panel.
    4. The operator will consider the complaint within 14 days of its receipt. The reply will be sent to the User using the contact form available from the Transaction Panel.
    §21 Termination of the contract
    1. The User may at any time resign from the services provided by the Operator.
    2. The User using the contact form in the Transaction Panel reports resignation from the services provided by the Operator.
    3. The Operator deletes the User's Account and all data identifying the User.
    4. The User can not terminate the contract if unsettled transactions and financial operations remain between the User and the Operator.
    §22 Amendments to Regulations
    1. Regulations may be amended by the Operator’s Management Board.
    2. Amendments to the Regulations come into force within 7 days from the date they are placed on the Website. The User will be informed about the changes by means of a message on the Website main page and a message available in the Transaction Panel.
    3. Logging into the Transaction Panel and failure to notify non-acceptance of the Regulations means acceptance of the amendments to the Regulations.
    4. Non-acceptance of the Regulations shall be performed by the User by a notice using the contact form in the Trading Panel. Non-acceptance of the Regulations shall preclude the use of the User Account, subject to the provisions of §21(4).
    5. In matters not provided for in these Regulations, the provisions of the Polish law shall apply, including in particular the provisions of the Foreign Exchange Law.
    6. Regulations come into force on January 1, 2014. website uses cookies. By using the website you agree to the use of cookies. More information here
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