📜 ELECTRONIC SIGNATURE POLICY

(Signature Policy & Audit Policy)

1. Purpose of the Document

This policy describes the rules and procedures for creating, signing, protecting, and storing electronic documents signed through an internal electronic signature system used by Tracksport.

The policy aims to ensure:

• authenticity of documents,
• integrity and immutability of content,
• traceability of the signing process.

2. Scope

The policy applies to the following types of documents:

• liability waivers;
• consents for personal data processing;
• other internal declarations signed by individuals.

The policy does not apply to documents for which the law requires a qualified electronic signature or notarial form.

3. Types of Signatures

3.1. Handwritten Electronic Signature of the Signatory

The signatory places a handwritten electronic signature using an electronic signing device (signature pad / tablet), capturing:

• the graphical representation of the signature;
• dynamic parameters (e.g., temporal and spatial characteristics);
• date and time of signing.

This signature constitutes a simple electronic signature within the meaning of Regulation (EU) 910/2014 (eIDAS).

3.2. Cryptographic Signature of the Document

After placing the handwritten electronic signature, the document is protected with an electronic signature created using a cryptographic certificate managed by Tracksport.

This signature:

• certifies the integrity of the document;
• prevents undetectable changes;
• certifies the moment of document finalization.

The signature does not constitute a qualified electronic signature within the meaning of eIDAS.

4. Signing Process

The signing process follows these steps:

1. Identification of the signatory through provided data.
2. Visualization of the document for review.
3. Placement of handwritten electronic signature via electronic device.
4. Generation of electronic document in PDF format.
5. Cryptographic signing and locking of the PDF document.
6. Recording of audit information (audit trail).

The document is considered final and valid after successful completion of all steps.

5. Audit Trail

An immutable audit trail is created for each signature, containing at least:

• unique document identifier;
• date and time of signing (local and UTC time);
• signatory identifier;
• document hash value;
• signing device information (model, serial number);
• certificate identifier used;
• software version used.

The audit trail is stored in append-only mode and is not subject to editing or deletion.

6. Storage and Protection

• Signed documents are stored in an electronic archive.
• Documents are protected against subsequent modifications.
• Access to the archives is restricted and controlled.

7. Limitations and Declaration

Electronic signatures used under this policy:

• do not constitute a qualified electronic signature;
• are not intended for transactions requiring special legal form.

This system is intended for internal and organizational processes requiring demonstrable consent from the signatory.

8. Effective Date

This policy becomes effective on January 06, 2026 and applies to all documents signed through the system after this date.