Legal

Refund Policy

Last updated 28 June 2026

1. Scope, definitions, and mapping note

1.1 Scope. This Refund Policy governs refunds, credit reversals, and chargebacks for all paid products supplied through the ewpire platform at ewpire.com (the "Service"). It forms an integral part of, and is to be read together with, the ewpire Terms of Service and Privacy Policy. In the event of a conflict between this Policy and the Terms of Service on a refund-specific matter, this Policy controls; on all other matters, the Terms of Service control.

1.2 Operator. The Service is operated by LeMans Labs OÜ ("ewpire", "we", "us", "our"), a private limited company registered in the Republic of Estonia (registry code 16872044), with its registered address at Valukoja 8/1, 11415 Tallinn, Estonia.

1.3 Definitions. Capitalised terms used but not defined here have the meaning given in the Terms of Service. In addition:

  • "Credit" – a unit of prepaid platform currency, the anchor reference value of which is approximately USD 0.10 per Credit . Credits are the sole means by which paid platform actions are metered.

  • "Subscription Credits" – Credits granted by an active monthly or annual Subscription Plan (Starter, Pro, or Business). On a monthly plan, Subscription Credits are renewed each billing month and expire at the end of the month in which they are granted (use-it-or-lose-it). On an annual plan, the full year's Subscription Credits are granted as a single pool valid for the 12-month term (no monthly expiry). This is described in the Terms of Service.

  • "Pack Credits" – Credits purchased as a one-time top-up package (a "Credit Pack"). Pack Credits are valid for ninety (90) days from the date of purchase.

  • "Consumed" – a Credit is Consumed when it has been debited from the User's balance to perform a Paid Action that returned a Result.

  • "Paid Action" – any platform action that debits Credits, including without limitation: an Ideation consensus run (a startup-idea analysis report with confidence and dissent map); a Validation build action (a sandboxed MVP build, preview, or deploy); and a Traffic action (an AEO/GEO presence generation run or a consensus brand-truth audit).

  • "Result" – the deliverable of a Paid Action – for Ideation, a generated report; for Validation, a completed build artefact, preview, or deployment; for Traffic, generated presence assets or a completed audit.

  • "Technical Failure" – a failure attributable to ewpire (or to a sub-processor engaged by ewpire) that prevents a Paid Action from producing its Result, as defined in §5.

1.4 Mapping note – why the prior model does not carry over. The prior Terms operated a subscription product and offered (i) a 14-day full money-back guarantee on the first subscription payment (§4.12), (ii) an earned-discount pro-rata refund on annual subscriptions cancelled mid-term (§4.14), and (iii) a "final sale, refund only on technical failure" rule for one-time AI Presence Scan reports (§25). v3 is a credit/usage product: value is delivered the instant a Result is produced, and each Result is performed immediately and irreversibly. A "money-back guarantee on a subscription" therefore does not map onto v3, because a User who has Consumed Credits has already received the digital service in full. Sections §3 (unused Credits), §4 (Consumed Credits non-refundable), and §5 (Technical-Failure auto-refund) are the proposed replacement for prior §4.12, §4.14, and §25. The prior §4.14 earned-discount annual pro-rata refund is not carried over in pro-rata form; instead, annual Subscriptions are addressed through the unused-Credit cooling-off period in §3 and the cancellation rules in §6.

2. Statutory cooling-off and immediate-supply waiver (EU / UK)

2.1 General position. The Service is offered primarily to businesses and to individuals acting in their professional capacity (see Terms of Service §2.1). Consumer withdrawal rights under Directive 2011/83/EU and equivalent distance-contract rules apply only where mandatory law extends them to the User.

2.2 Immediate performance and express waiver. Each Paid Action is a contract for the supply of digital content not supplied on a tangible medium, performed immediately upon the User's request. Pursuant to Article 16(m) of Directive 2011/83/EU, as transposed into Estonian law by § 53(4) clause 13 of the Law of Obligations Act (Võlaõigusseadus) , the statutory 14-day right of withdrawal does not apply to a Consumed Credit / completed Paid Action where, in line with Article 8(7) of Directive 2011/83/EU, the three cumulative conditions are met: (a) the User has given prior express consent to immediate performance; (b) the User has acknowledged that the right of withdrawal is lost once performance has begun and the digital service has been fully supplied; and (c) ewpire has provided confirmation of that prior consent and acknowledgment on a durable medium. A durable-medium waiver confirmation (a confirmation email recording the consent and acknowledgment) is sent to the User after the relevant purchase or Paid Action.

2.3 How consent and waiver are collected. At the first paid purchase, the checkout flow requires the User to accept, through an acceptance step that is not pre-ticked and is presented together with acceptance of the Terms, the following before payment completes:

"I request that ewpire begin supplying the digital service (a consensus report, a build, a Traffic run, or the purchase of Credits) immediately. I understand that if I am located in the European Union or the United Kingdom, once a paid action has been supplied I lose my 14-day right of withdrawal for that action under Article 16(m) of Directive 2011/83/EU (and Regulation 37(1)(a) of the UK Consumer Contracts Regulations 2013)."

Pre-ticked checkboxes are not used, consistent with Case C-673/17 (Planet49) and Article 7(2) GDPR. The exact text shown, together with the timestamp, a hashed (non-reversible) record of the IP address, the user agent, and the version hash of the disclosure, is recorded in an immutable consent log, and a durable-medium confirmation of the consent and acknowledgment (per §2.2) is sent to the User. The log is retained for no less than three (3) years from the relevant transaction as evidence of contractual performance, on the limitation-period basis in § 146 of the Estonian Law of Obligations Act (Võlaõigusseadus).

2.4 Online withdrawal. Where a withdrawal right applies (i.e. for an unconsumed Credit Pack still within its 14-day window – see §3), the User may exercise it online from within their account: a clearly labelled withdrawal control in Account Settings lets the User submit a withdrawal declaration for an in-window Pack purchase, and on submission ewpire provides an on-screen acknowledgment and sends the User a confirmation of receipt on a durable medium (a confirmation email recording the content of the withdrawal and the date of receipt) without undue delay.

2.5 Relationship to this Policy. The unused-Credit refund in §3 is offered independently of, and in addition to, the statutory withdrawal right, so that EU and UK Users retain a substantively equivalent cooling-off remedy in practice for value they have not yet consumed.

3. Unused Credits – 14-day cooling-off refund

3.1 Refund of unused Credits. You are entitled to a refund of Credits that have not been Consumed, requested within fourteen (14) calendar days of the purchase that granted them, provided that no Credits from that purchase have been Consumed. This covers both Subscription Credits (the first month's grant under a new Subscription) and Pack Credits. Where the withdrawal is valid, the refund is the full amount paid for the unconsumed Credits with no fee or transaction-cost deduction, consistent with the reimbursement-without-deduction rule in Article 13 of Directive 2011/83/EU; ewpire absorbs any Stripe processing fee rather than passing it to the User.

3.2 Use extinguishes the withdrawal right for the whole purchase. The Credits in a purchase are digital content made available to the User immediately on payment. Where the User begins to use the Service by Consuming any Credit from that purchase, performance has begun at the User's express request and – pursuant to the prior express consent and acknowledgment captured at checkout (§2.2) – the 14-day right of withdrawal is extinguished for the entire purchase under Article 16(m). The purchase is then non-refundable in full (both the Consumed Credits and any Credits that remain unconsumed). A purchase is therefore refundable under §3.1 only while it remains wholly untouched – only while no Credit from it has been Consumed. This single, clearly-disclosed rule (untouched ⇒ full refund within 14 days; used at all ⇒ no refund) applies uniformly to Packs and to the first grant of a new Subscription, consistent with the immediate-supply waiver in §2 and the Pack rule in §6.3.

3.3 Mixed balances. Where a User holds a mixed balance (e.g. carried-over Pack Credits plus a fresh Subscription grant), consumption is deemed to draw down Credits in the order that protects the User's refund rights least adversely .`

3.4 Procedure. To request a cooling-off refund, either use the in-account withdrawal control (§2.4) or contact support at [email protected] (see §10) within the 14-day window, identifying the purchase. Approved refunds are processed to the original payment method via Stripe Payments Europe Limited and/or other Stripe entities as applicable within five (5) to ten (10) business days. Upon refund, the corresponding unconsumed Credits are removed from the User's balance.

3.5 Expired Subscription Credits. Subscription Credits that have expired under the use-it-or-lose-it rule are not refundable, as they represent a lapsed monthly allowance rather than a stored balance. This forfeiture applies only where the monthly expiry has been conspicuously disclosed to the User before purchase (at the point of sale and in the plan description); absent such pre-purchase disclosure, the forfeiture is not relied upon.

4. Consumed Credits – non-refundable

4.1 Final supply. Subject to §5 (Technical Failure), Consumed Credits are non-refundable. A Paid Action that has returned a Result – a consensus report, a build, a Traffic run, or an audit – is a digital service performed immediately and irreversibly. Performance is complete at the moment the Result is generated and made available to the User.

4.2 No refund on dissatisfaction. No refund or Credit reversal will be issued on grounds of dissatisfaction with a Result's content, conclusions, methodology, confidence score, dissent map, scope, market-sizing estimates (TAM/SAM/SOM), generated code, generated presence assets, or commercial utility. Each Result is structured deliberation and an estimate, provided "as is" pursuant to the Limitation of Liability in the Terms of Service. ewpire does not provide advice and does not guarantee any outcome; Traffic outputs are framed as increasing the probability of accurate, consistent description and never as guaranteed visibility. The confidence score and dissent map are an integral part of this disclosure.

4.2a AI transparency (no effect on refund rights). Results are AI-generated. From 2 August 2026, the transparency duties of Article 50 of the EU AI Act (Regulation (EU) 2024/1689) apply: ewpire (as provider) and the User (as deployer) each carry duties. ewpire discloses that the Ideation chat is an interaction with an AI system (Art. 50(1)); marks AI-generated outputs – Validation code and Traffic content – in a machine-readable format as artificially generated (Art. 50(2)); and, where any output is synthetic image, audio, or video, or AI-generated text published to inform the public, supports the relevant disclosure (Art. 50(4)). These obligations are detailed in the Terms of Service / AI-transparency notice (with reference to the 10 June 2026 Code of Practice) and do not themselves create or remove any refund right under this Policy.

4.3 Tie to the withdrawal waiver. Non-refundability of a Consumed Credit follows directly from the Article 16(m) immediate-supply waiver in §2: the User expressly consented to immediate performance and acknowledged the loss of the withdrawal right for that action once supplied.

5. Technical-Failure exception – auto-refund / no charge

5.1 Principle (mirrors engine behaviour). Where a Paid Action fails to deliver a Result due to a Technical Failure, the Credits for that action are not charged, or, if already debited, are automatically refunded to the User's Credit balance. This mirrors the implemented engine behaviour, in which a consensus run that does not complete does not charge the User.

5.2 Qualifying failures. A Technical Failure includes, without limitation: (a) an engine or orchestration failure resulting in no Result being generated; (b) failure of the consensus LLM providers such that no usable consensus output can be produced; (c) a Validation build that fails in the sandboxed runtime through no fault of the User's instructions, or a deploy that fails on the hosting target attributable to ewpire; (d) a Traffic run that produces no presence assets or no audit result; or (e) a corrupted, empty, or undeliverable Result artefact.

5.3 Exclusions. This exception does not extend to: (a) dissatisfaction with a delivered Result (see §4.2); (b) a Result the User considers inaccurate where a Result was nonetheless generated; (c) outcomes dependent on the quality or completeness of the User's own inputs (idea text, interview answers, brand/site content, build instructions); (d) volatility or change in how third-party AI assistants describe a brand over time (an inherent characteristic of the Traffic product, not a Technical Failure); or (e) third-party platform-side delays, rejections, or outages outside ewpire's control (e.g. a deploy rejected by the hosting provider for the User's content).

5.4 Form of remedy. The default remedy for a Technical Failure is re-credit of the affected Credits to the User's balance (so the User may re-run the action), rather than a cash refund. Where Credits cannot be re-credited (e.g. the underlying purchase has been fully refunded or the account closed), a cash refund of the corresponding value is issued to the original payment method within fourteen (14) calendar days.

5.5 Reporting window. Automatic re-credit on detected failure requires no action by the User. Where the User believes a Technical Failure was not auto-detected, the User should contact support at [email protected] (see §10) within fourteen (14) calendar days of the affected action, providing the action reference. This reporting window does not limit any longer statutory remedy under §9.

6. Subscription cancellation, renewals, and packs

6.1 Cancellation (easy cancel). You may cancel a Subscription at any time, by the same ease of means used to subscribe, via Account Settings or the Stripe Customer Portal – a single, clearly labelled cancellation control ("click-to-cancel"), without retention steps, phone calls, or other obstacles. Cancellation takes effect at the end of the current billing period; you retain access and any unexpired current-month Subscription Credits until the end of that period. No refund is issued for partial months, save for the cooling-off refund in §3 or where mandatory law requires otherwise.

6.2 Renewals and auto-renewal transparency. Subscriptions renew automatically (monthly or annually) until cancelled. Before purchase, ewpire conspicuously discloses that the plan auto-renews, the renewal cadence, the renewal price, and how to cancel; for annual plans, ewpire sends a pre-renewal reminder where required by applicable law. Cancellation is available at any time by the easy-cancel means in §6.1, and – for the withdrawal window on an unconsumed Pack – through the in-account withdrawal control in §2.4. The 14-day cooling-off refund in §3 applies to the first purchase that grants Credits; subsequent renewal payments are non-refundable once their Credits are made available, except as required by mandatory applicable law (see §9). Annual plans grant the full year's Subscription Credits as a single pool valid for the 12-month term (no monthly expiry on annual); ewpire does not offer the prior pro-rata earned-discount refund on annual cancellation, provided that the absence of a pro-rata refund is conspicuously disclosed before the annual purchase.

6.3 Credit Packs. Pack Credits are valid for 90 days and are non-refundable once any Credit from the Pack has been Consumed (§4); an entirely unconsumed Pack is refundable within the §3 cooling-off window. Expiry of unused Pack Credits after 90 days does not give rise to a refund, provided the 90-day validity is conspicuously disclosed at the point of sale and reinforced by an expiry-reminder notification before lapse.

6.4 No BYOK at launch. v3 does not offer "bring your own key" at launch; ewpire supplies its own provider tokens, metered as Credits. There is accordingly no separate BYOK fee, pass-through, or refund mechanic.

6.5 Pause / withdrawal of a product. Where ewpire pauses, restricts to a waitlist, or withdraws a product or feature (for re-architecture, capacity, compliance, security, or platform migration), existing prepaid balances are honoured or, where continued operation is not reasonably possible, the User is offered re-credit or a refund of the unused prepaid portion at ewpire's election. A pause alone does not trigger a refund obligation provided service resumes within thirty (30) days or the User is offered a refund of any unused prepaid balance.

7. VAT handling on refunds

7.1 Economic base and currency. Credits and Subscriptions are priced on a USD economic base and are exclusive of VAT. The currency actually charged is determined by Stripe based on the User's location and payment method.

7.2 VAT on refunds. Where a refund is issued, any VAT, sales tax, or equivalent indirect tax that was charged on the original transaction is refunded together with the net amount, in the same proportion as the refund bears to the original charge. VAT is calculated and reversed automatically by Stripe Tax (provided by Stripe Payments Europe Limited and/or other Stripe entities as applicable). For EU customers, VAT is collected and, on refund, adjusted by LeMans Labs OÜ under the Estonian One-Stop-Shop (OSS) scheme; the applicable tax category is Electronically Supplied Services.

7.3 Reverse charge. EU business customers who applied the reverse-charge mechanism (0% VAT) at purchase via a valid VAT identification number receive a refund of the net amount only, as no VAT was charged.

7.4 Partial refunds. On a partial refund (e.g. a re-credit of a subset of an action's Credits, or a refund of part of a mixed balance), VAT is reversed pro rata to the refunded portion.

8. Chargebacks

8.1 Contact support first (request). Before initiating any payment dispute or chargeback with your card issuer or bank, we ask that you contact ewpire support first at [email protected] (see §10), so that a qualifying refund under this Policy can be processed directly and faster. This is a request and does not limit your right to raise a dispute with your card issuer or bank.

8.2 Effect of chargebacks. Where a chargeback reverses a payment, the Credits funded by that payment are removed from the User's balance to the extent they were not consumed. Merely disputing a charge does not, by itself, result in account suspension or recovery of dispute / chargeback fees from the User. ewpire reserves the right to contest chargebacks it considers unwarranted, using the consent and delivery records described in this Policy as evidence, and may take account-level action only in cases of fraud or abuse.

8.3 Referral clawback. A chargeback or refund that reverses a referred User's first deposit triggers clawback of any related referral commission under §11.

9. Relationship to mandatory consumer rights

9.1 No limitation of mandatory rights. This Policy is a voluntary commercial framework. Nothing in it limits or waives any mandatory consumer-protection right that applies to a User resident in the European Union, the United Kingdom, or another jurisdiction with stricter consumer-protection law. Where applicable mandatory law grants a remedy more generous than this Policy, that law prevails.

9.2 Statutory conformity remedies for digital content (Directive (EU) 2019/770). Where the User is a consumer, the digital content and digital services supplied through the Service must conform to the contract. Nothing in this Policy affects the consumer's mandatory non-conformity remedies under Directive (EU) 2019/770 (as transposed into Estonian law), which apply for the relevant statutory period (up to two (2) years from supply, or for the duration of continuous supply). Where a Result or Paid Action is non-conforming, the consumer is entitled to have it brought into conformity, or to a proportionate price reduction or termination with a refund, in the cases and on the conditions set out in that Directive. These statutory remedies are in addition to the contractual remedies in §3–§5 and prevail over any narrower term in this Policy.

9.3 Out-of-court dispute resolution. The EU Online Dispute Resolution platform was permanently discontinued on 20 July 2025 and is no longer available; the former EU ODR web platform is not referenced. A consumer in the EU/EEA may instead bring a dispute to a national alternative-dispute-resolution body – for Estonia, the Consumer Disputes Committee (Tarbijavaidluste komisjon, komisjon.ee).

10. How to request a refund / contact

To request a refund, report a Technical Failure, or raise a billing question, contact ewpire support, identifying the relevant purchase or action reference:

LeMans Labs OÜ Valukoja 8/1, 11415 Tallinn, Estonia Support and billing: [email protected] Privacy / data-subject requests: [email protected] Legal notices: [email protected] Website: ewpire.com

You may also exercise the 14-day withdrawal right online via the in-account withdrawal control described in §2.4. Approved refunds are processed to the original payment method via Stripe Payments Europe Limited and/or other Stripe entities as applicable. Re-credits are applied to the User's Credit balance immediately on approval or automatic detection.

11. Referral commissions – refunds, clawback, and tax

11.1 v3 referral structure. Where a person you refer makes their first deposit (their first paid Credit purchase or first Subscription payment), you earn a one-time commission equal to 20% of that first deposit (excluding VAT), provided your own ewpire subscription is active. The commission is held for about 30 days (until the refund/chargeback window has cleared) and then paid via Stripe Connect Express, with no minimum payout threshold. Attribution is by a persistent first-party referral cookie with a 30-day click-attribution window, set only with the referred User's consent.

11.2 Clawback on refund or cancellation. If the referred User refunds, charges back, or cancels before the commission is paid out, the commission is clawed back (cancelled) in full. Where a refund or chargeback occurs after payout, ewpire may recover the corresponding amount from future referral earnings or by direct recovery. A refund issued under §3 (unused Credits), §5 (Technical Failure resulting in cash refund of the first deposit), or a chargeback under §8 each triggers clawback to the extent it reverses the qualifying first deposit.

11.3 Disclosure obligation. Referrers must clearly and conspicuously disclose the referral relationship wherever they promote ewpire, in accordance with the U.S. FTC Guides Concerning the Use of Endorsements and Testimonials, the EU Unfair Commercial Practices Directive (2005/29/EC), the UK CAP/CMA rules, and the transparency obligations of the EU Digital Services Act (Regulation (EU) 2022/2065). Self-referrals are prohibited. Referral links may not be promoted through spam, misleading advertising, or any method that violates applicable law; ewpire may disqualify referrals and withhold or claw back commissions in cases of fraud or abuse.

11.4 Tax responsibility (no withholding, no tax advice). Referral commissions constitute taxable income. Each Referrer is solely responsible for reporting and paying all applicable taxes (including income tax, VAT / GST, self-employment tax, social-security contributions, and any withholding tax) on commissions received, in accordance with the laws of the Referrer's country of tax residence. LeMans Labs OÜ does not withhold taxes on commissions and does not provide tax advice. The Referrer warrants that it has consulted its own tax advisor before accepting commissions, and ewpire disclaims all liability for the Referrer's tax compliance or non-compliance.

11.5 VAT place of supply. Whether the referral commission is treated as consideration for a supply for VAT purposes, and the place of supply thereof, depends on the Referrer's status and location; the Referrer is responsible for any VAT it must account for.

11.6 Tax-onboarding and DAC7 (no reporting role asserted). As part of payout onboarding, ewpire (through its payment partner) may collect Form W-9 / W-8BEN via Stripe (Stripe Connect). DAC7 (Directive (EU) 2021/514) applies to platform operators that intermediate certain reportable activities (the sale of goods, personal services, immovable-property rental, and rental of means of transport); it does not cover affiliate, referral, or advertising commissions. ewpire therefore does not assert a DAC7 platform-operator reporting role in respect of referral commissions, and assumes no withholding or tax-advisory obligation; the W-9 / W-8BEN collection is for payout onboarding only.

11.7 Governing law of the programme. The Referral Programme is governed by Estonian law (LeMans Labs OÜ, registry 16872044) and by the Referral Programme Terms published on ewpire.com.

12. Records and data protection

12.1 Consent and delivery records. ewpire retains records evidencing consent to immediate supply (§2), Paid Action delivery, and refund decisions – including timestamp, hashed IP and user agent, disclosure-version hash, and order / action reference – for three (3) years from the relevant transaction, as evidence of contractual performance, on the limitation-period basis in § 146 of the Estonian Law of Obligations Act (Võlaõigusseadus).

12.2 Billing, referral, and financial records. Billing records, invoices, and referral / financial records are retained for seven (7) years on the lawful basis of legal obligation under Article 6(1)(c) GDPR and the Estonian Accounting Act (Raamatupidamise seadus), regardless of refund or account status.

12.3 Deletion and right to erasure. A refund does not by itself trigger erasure. On account termination, live-system data is deleted within thirty (30) days, and ewpire certifies that live deletion within 30 days. Data residing in backups is not restored except for disaster recovery, is kept encrypted, and is overwritten on a rolling cycle of at most ninety (90) days. The User's right to erasure under Article 17 GDPR is honoured within thirty (30) days of a verified request, except where retention is mandated under §12.1–§12.2 (including the 7-year referral/financial-records carve-out), in which case ewpire informs the User of the legal basis and scope of the retained data.

12.4 Sub-processor and transfer context. Performing a Paid Action transmits the User's inputs (idea text, interview answers, brand/site content, and, for Validation, generated code) to multiple frontier LLM providers for inference, and Validation builds run in a sandboxed runtime; refund determinations may reference logs held across these sub-processors. The identity of sub-processors, the no-training commitment, the multi-provider sharing, and the Standard Contractual Clauses (Module 2) plus transfer-impact-assessment safeguards for non-EEA providers (including the heightened scrutiny applied to China-based providers) are set out in the Privacy Policy and the DPA sub-processor annex, not in this Policy.

13. Governing law and jurisdiction

13.1 Governing law. This Policy is governed by the laws of the Republic of Estonia, without regard to conflict-of-laws principles. Mandatory provisions of European Union law apply where applicable.

13.2 Jurisdiction. Any dispute arising out of or in connection with this Policy that cannot be resolved amicably within thirty (30) days of written notice shall be submitted to the exclusive jurisdiction of the Harju County Court (Harju Maakohus), Tallinn, Estonia, except where the User is a consumer resident in the European Union or the United Kingdom and mandatory consumer-protection law of the User's country of habitual residence grants the User the right to bring proceedings before, or to be sued in, the courts of that country – in which case those mandatory rules prevail.

13.3 Language. This Policy is drafted in English. In the event of any translation, the English version prevails.