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Refund & EU Withdrawal Policy

Last Updated: July 6, 2026 · Effective: June 11, 2026 · Version 1.1 (Vireks v1)

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 the Vireks one-time €5 Unlock and supplements the Terms of Service.

Issued by: ZADIO EOOD · EIK 201209745 · VAT BG201209745 · app@zadio.bg

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 of the Vireks Unlock. 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 app@zadio.bg. 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 Scope

If you are a Consumer resident in the EU/EEA, you have the right to withdraw from the distance contract for the Vireks Unlock without giving any reason within 14 days from the day of conclusion of the contract (Article 9 CRD; for digital content, “conclusion” corresponds to the moment Google Play confirms the purchase to you and to us).

4.2 Article 16(m) waiver — the realistic position

Under Article 16(m) CRD, the right of withdrawal does NOT apply to contracts for the supply of digital content not on a tangible medium if performance has begun with the Consumer’s prior express consent and explicit acknowledgement that the right of withdrawal will thereby be lost. Google Play’s purchase flow obtains that consent and acknowledgement at the moment you tap “Buy” on the Unlock purchase dialog. The functional consequence is that, once you have begun using a Recording produced after the Unlock was applied, the 14-day withdrawal period is consumed and the right cannot be exercised.

4.3 The free quota exists for exactly this reason

The three (3) free, full-quality Recordings you can make before the Unlock is required are intended to give you a complete demonstration of the real product before the withdrawal right is consumed. Use them. Verify that:

If any of those is a deal-breaker, do not purchase the Unlock. If all of those work, the Unlock is the product you tested.

4.4 If you are entitled to withdraw

If you are within a fact pattern where the Article 16(m) waiver does NOT apply (for example, you purchased the Unlock and have not yet made any post-Unlock recording, OR Google Play’s purchase flow failed to obtain the required express consent on your locale), then:

5. Conformity of Digital Content (DCD remedies)

Separate from the right of withdrawal, you have a statutory right to digital content that is in conformity with the contract, under Directive (EU) 2019/770 (DCD) and the Bulgarian Digital Content Act. “Conformity” means, broadly, that the App matches the description and functional promises in these Terms and the marketing page, and is reasonably free of defects.

If the App is non-conforming — for example, it crashes when you press Start on a supported Android version; the Unlock fails to restore on a new device on the same Google account; an advertised feature (MP4 output, microphone audio, the corner-tap stop) is unusable; the App is not actually free of INTERNET permission as claimed in our marketing — you have the following remedies, in order:

  1. Bring into conformity (Art. 14(1) DCD): we will attempt to fix the non-conformity within a reasonable time, free of charge, and without significant inconvenience to you.
  2. Proportionate price reduction (Art. 14(4) DCD): if bringing the App into conformity is impossible, would entail disproportionate costs to us, or was not achieved within a reasonable time.
  3. Termination of the contract and full refund (Art. 14(4) DCD): in the most serious cases of non-conformity, or where the previous remedies are unavailable.

The hierarchy of remedies is consumer-friendly: you do not have to start at the bottom. You may go straight to termination if the non-conformity is "not minor" within the meaning of Article 14(6) DCD.

Refunds under these remedies are processed via Google Play as described in §3.

6. How to request a remedy or refund

6.1 First step — tell us

Email app@zadio.bg with:

We will acknowledge within 3 business days and either (i) walk you through a fix, (ii) confirm that the issue is non-conformity and start the remedy process, or (iii) explain why we believe the App is in fact conforming on your scenario.

6.2 Parallel step — Google Play

You may also (or instead) lodge a refund request directly via Google Play’s refund flow (see §3.2). Google Play applies its own commercial refund policy, which is generally generous within the first 48 hours of purchase. If Google Play refunds you, the matter is closed.

6.3 If Google Play declines

If Google Play declines but you are nonetheless entitled to a statutory remedy under EU/Bulgarian law, reply to our email correspondence (or open one if you have not already) with the Google Play reference, and we will work with Google Play to issue the reimbursement. Where this fails for reasons outside our control, we will provide the lawful remedy directly (e.g. a SEPA transfer for the relevant amount).

7. Out-of-court dispute resolution

7.1 EU Online Dispute Resolution (ODR) platform

Pursuant to Regulation (EU) 524/2013, EU consumers may use the European Commission’s ODR platform to submit complaints:

ODR platform: https://ec.europa.eu/consumers/odr
Our contact for ODR: app@zadio.bg

7.2 Bulgarian conciliation commissions

For consumer disputes in Bulgaria, free conciliation commissions are organised by the Commission for Consumer Protection: www.kzp.bg.

7.3 Participation in ADR

We are not obliged to, and do not undertake to, participate in any specific alternative-dispute-resolution scheme beyond the statutory framework described above. We will, however, respond to communications from ADR bodies in good faith.

8. Judicial redress

Subject to the consumer jurisdictional rules of Articles 17-19 of Regulation (EU) 1215/2012 (Brussels I recast), a Consumer may bring proceedings against ZADIO EOOD either in the courts of Bulgaria or in the courts of the EU Member State where the Consumer is domiciled, and may be sued only in the courts of the EU Member State where the Consumer is domiciled.

9. Contact

ZADIO EOOD · EIK 201209745 · VAT BG201209745
Registered seat: Ploshtad Han Kubrat 1, 7000 Ruse, Bulgaria, EU
Email: app@zadio.bg
Website: https://zadio.bg/vireks

Annex A — Model Withdrawal Form

You may copy, complete, and email the following form to app@zadio.bg. You are not required to use this exact form; any clear statement of your decision to withdraw is sufficient.

To: ZADIO EOOD, Ploshtad Han Kubrat 1, 7000 Ruse, Bulgaria — app@zadio.bg

I/We (*) hereby give notice that I/we (*) withdraw from my/our (*) contract of sale of the following goods (*) / for the supply 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.