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Refund & EU Withdrawal Policy

Last Updated: April 19, 2026 · Effective: April 19, 2026 · Version 2.0

This Refund and Withdrawal Policy describes your rights as a Consumer to withdraw from distance contracts and to seek remedies for non-conforming Digital Content, and the procedures for requesting refunds. It applies to purchases of MindLotus subscriptions and individual Marketplace items and supplements the Terms of Service.

Issued by: Zadio EOOD · EIK 201209745 · VAT BG201209745 · mindlotus.app@gmail.com

Contents

  1. Legal framework
  2. Who is a Consumer?
  3. Role of Google Play
  4. Right of withdrawal (14 days)
  5. Conformity of Digital Content
  6. How to request a remedy or refund
  7. Out-of-court dispute resolution
  8. Judicial redress
  9. Contact
  10. Annex A — Model Withdrawal Form

1. Legal Framework

2. Who is a Consumer?

A “Consumer” is any natural person acting for purposes outside their trade, business, craft, or profession. Business buyers (B2B) do not benefit from the consumer-withdrawal right but may benefit from warranty rights under general civil law.

3. Payments and Refunds — Google Play only

All payments are collected by Google Play. Google Play acts as the merchant of record for EU/EEA end-user purchases. We do not collect payments directly, and therefore we do not and cannot process refunds to your card, bank account, mobile wallet, carrier-billing account, or any other payment instrument. All refund requests must be submitted to Google Play.

3.1 What Google Play handles

3.2 How to request a refund

Submit your request directly to Google Play:

3.3 Statutory consumer rights — safety net

Your mandatory rights under EU/Bulgarian consumer law — including (where applicable) the 14-day right of withdrawal (Section 4) and the Digital Content Directive remedies for non-conformity (Section 5) — apply regardless of Google Play’s commercial refund policy. If Google Play declines a refund but you are nonetheless entitled to a remedy under mandatory law, contact us at mindlotus.app@gmail.com. We will work with Google Play to ensure the reimbursement is processed, or — exceptionally, where Google Play is unable to act — provide the lawful remedy directly. In no case will we charge you a fee for a statutory reimbursement.

4. Right of Withdrawal (14 Days)

4.1 The right

If you are a Consumer in the EU/EEA, you have the right to withdraw from your contract within 14 calendar days from the day of conclusion, without reason and without cost (other than those provided by law).

4.2 Exception for digital content

The right of withdrawal does not apply to a contract for the supply of digital content which is not supplied on a tangible medium, if performance has begun with your prior express consent and your acknowledgement that you thereby lose your right of withdrawal (CRD Art. 16(m); Bulgarian CPA Art. 57, item 13).

By confirming the purchase of a Subscription or Marketplace item in Google Play and beginning to use the App immediately, you are deemed to have provided both (a) express consent and (b) acknowledgement — and the right of withdrawal is therefore waived for that specific purchase.

4.3 When the exception does NOT apply

The right of withdrawal remains available where: (a) you were not informed of the loss of the right prior to performance; (b) you did not give prior express consent to immediate performance; or (c) performance has not in fact begun.

4.4 Free Trial

The Free Trial is free and does not give rise to a right of withdrawal. You may simply stop using the App at any time during the trial.

4.5 How to withdraw

Notify us by:

We will acknowledge receipt on a durable medium (email) without undue delay.

4.6 Effects of withdrawal

5. Conformity of Digital Content

5.1 Conformity requirement (DCD Arts. 6–8; Bulgarian DCA)

We supply Digital Content that:

5.2 Liability period (DCD Art. 11)

For ongoing supply (Subscriptions): throughout the entire period of supply. For one-off supply (Marketplace items): where the lack of conformity appears within two (2) years from supply.

5.3 Remedies hierarchy (DCD Art. 14)

Step 1 — Bring the Content into conformity. We will repair or update the Content within a reasonable time, free of charge, without significant inconvenience to you.

Step 2 — Proportionate price reduction OR termination. You may request a price reduction or terminate the contract if:

If you elect to terminate for non-conformity, we reimburse amounts paid for the non-conforming supply period, within 14 days.

5.4 No remedy where you caused the problem

No remedy is due where the lack of conformity results from a failure on your part — for example, if your device does not meet the minimum system requirements communicated to you at the point of purchase.

6. How to Request a Remedy or Refund

Email mindlotus.app@gmail.com including:

  1. Your name and order reference (Google Play order number if available)
  2. Date of purchase
  3. Description of the issue and the remedy you seek (repair, price reduction, termination, or withdrawal)
  4. Any supporting screenshots or device information

We acknowledge receipt within 3 business days and provide a substantive response as soon as reasonably possible, within statutory timeframes.

7. Out-of-Court Dispute Resolution

7.1 EU ODR platform

European Commission’s online-dispute-resolution platform: ec.europa.eu/consumers/odr. Our contact for ODR: mindlotus.app@gmail.com.

7.2 Bulgarian Commission for Consumer Protection (CCP)

Conciliation commissions of the CCP: www.kzp.bg.

7.3 Participation

We are not obliged to participate in any specific ADR scheme beyond the statutory framework above, but we will examine any complaint in good faith and respond within statutory deadlines.

8. Judicial Redress

Consumers retain the right to bring proceedings before the competent courts under Regulation (EU) 1215/2012 (Brussels I recast), including the courts of their country of habitual residence.

9. Contact

Zadio EOOD · EIK 201209745 · VAT BG201209745
Registered seat: Ploshtad Han Kubrat 1, 7000 Ruse, Bulgaria
Email: mindlotus.app@gmail.com
Website: https://mindlotus.app

Annex A — Model Withdrawal Form

(Directive 2011/83/EU, Annex I(B). Complete and return this form only if you wish to withdraw from the contract.)

To: Zadio EOOD, EIK 201209745, Ploshtad Han Kubrat 1, 7000 Ruse, Bulgaria, Email: mindlotus.app@gmail.com

I/We (*) hereby give notice that I/We (*) withdraw from my/our (*) contract of sale of the following goods (*) / for the provision of the following service (*):

_________________________________________________________

Ordered on (*) / received on (*): ____________________

Name of consumer(s): _________________________________

Address of consumer(s): ______________________________

Signature of consumer(s) (only if this form is notified on paper): ____________________

Date: __________________

(*) Delete as appropriate.