Refund and Cancellation Policy — draft

Prepared for review by licensed counsel. Not legal advice. Part B is the proposed public text; Parts A and C are internal. Part B may not be published while any bracket remains.

Part A — Drafting brief (internal)

Part B — Proposed public text

Refund and Cancellation Policy

Version: 1.0 [OPEN] · Effective: [OPEN: date]

This policy explains how to cancel a HidzoVPN subscription and when you can get a refund. It forms part of our Terms of Service. It is provided by HidzoVPN, Inc., a Florida corporation. "Premium" means the paid HidzoVPN plan described in our Terms of Service. Nothing in this policy limits any right you have under the law of the place where you live.

1. Cancel at any time

Except for cryptocurrency prepayments (Section 6) and Activation Codes (Section 5A), your subscription renews automatically until you cancel [ENGINEERING: confirm the renewal configuration in Stripe, Apple and Google — CLM-025]. Cancelling stops the next renewal. You keep Premium until the end of the period you have already paid for, unless you receive a refund [ENGINEERING: QN-08-020].

Deleting the app does not cancel your subscription. Deleting your account cancels the renewal of a website subscription [ENGINEERING: POL-DEL-001 §1], but not of an Apple or Google subscription.

To avoid being charged for the next period, cancel before the renewal time shown in your account or store. Times for website purchases are shown in [ENGINEERING: time zone].

European Union and United Kingdom: see Section 4 for your right to withdraw and get a refund.

1A. Subscriptions started before this policy

[OPEN — COUNSEL (BRF-2026-001 P1-2; RSK-012): remedy for website subscribers who enrolled under the Terms dated 1 September 2025, for example: "If you subscribed on our website before [date], we will ask you to confirm your subscription before your next renewal" or "you may request a refund of renewal charges made before [date]".]

2. Free trials

If you cancel a trial before the cancellation deadline, you will not be charged. For trials started through Apple, cancel at least 24 hours before the trial ends [VERIFY: Apple Support 118428; Google Play deadline]. When you start a trial on our website, we send you a confirmation that states the date the trial ends, the price that will be charged after it and a link to cancel online [ENGINEERING]. If you cancel a website trial, you keep Premium until the trial ends [ENGINEERING]. [OPEN: an additional reminder before the trial ends — timing; card-network rules require the reminder content for trials of 7 days or less to be in the sign-up confirmation — EV-406]

3. Refunds for purchases on our website

[OPEN — BRF-2026-001 D5: choose Alternative A or Alternative B and delete the other]

Alternative A — statutory refunds and discretionary review. We give refunds where the law requires it, including under Section 4. We also review other refund requests individually and may grant a full or partial refund, for example if you were charged by mistake or could not use the service because of a problem on our side.

Alternative B — 30-day refund on your first payment.

• First payment: you can request a full refund, including any tax charged, within [OPEN: 30] days of your first paid charge. You can use this once per person, account and payment method.
• Renewals: you can request a full refund of a renewal charge within [OPEN: 7] days of the renewal.
• Other requests are reviewed individually, and we will refund where the law requires it.

[COUNSEL: 16 C.F.R. Part 239 if "money-back" wording is used in advertising; add a claims-register entry before any marketing use]

Service failures (both alternatives): [OPEN: if Premium is unavailable for more than 72 consecutive hours because of a problem on our side, you can request a pro-rata refund or credit for that time].

How to request: email [email protected] from your account email, or include that address in your message, with the date and amount of the charge. Approved refunds are returned to the original payment method [OPEN: within X business days of approval]. Your bank may take longer to show the refund.

4. Right of withdrawal in the European Union and the United Kingdom

[COUNSEL: EU/UK consumer counsel to approve this section — EV-232]

4.1 If you live in the European Union or the United Kingdom and buy a subscription on our website, you can withdraw from the contract within 14 days after the day the contract is concluded, without giving a reason.

4.2 To withdraw, use the "Withdraw from contract here" function in your account, then confirm with "Confirm withdrawal"; we send you an acknowledgement by email straight away [ENGINEERING: withdrawal function, available throughout the withdrawal period — RSK-051]. You can also tell us clearly by email to [email protected]. You may use the model withdrawal form below, but you do not have to. If you cancel within the 14-day period, we will ask whether you also want to withdraw and receive a refund under this Section [ENGINEERING: prompt in the cancellation flow].

4.3 If you expressly asked us to start Premium during the withdrawal period and then withdraw, you pay only for the paid service provided until you told us, calculated day by day. You pay nothing for any free-trial period, and nothing at all if you did not make that request. We refund without undue delay and no later than 14 days after we receive your withdrawal, to the payment method you used, free of charge. [COUNSEL: confirm treatment of a VPN subscription as a service contract; checkout must capture the express request and acknowledgement — CRD Arts. 7(3), 8(8), 14(3)–(4); UK CCRs reg. 36]

4.4 For purchases through Apple, Apple handles withdrawals under its own process. For Google Play purchases [VERIFY: whether HidzoVPN or Google is the trader for EU/UK withdrawal purposes — EV-232].

Model withdrawal form

(complete and return this form only if you wish to withdraw from the contract) — To [OPEN: HidzoVPN, Inc., EU/UK business address — DEC-2026-001 §4.4; RSK-046], [OPEN: telephone], [email protected]: — I/We hereby give notice that I/We withdraw from my/our contract for the provision of the following service: HidzoVPN Premium — Ordered on — Name of consumer(s) — Address of consumer(s) — Signature of consumer(s) (only if this form is notified on paper) — Date (Optional: account email, to help us find your account.) [COUNSEL: optional field added to the CRD Annex I(B) model form — acceptable? Annex I(B) text verified first-hand, Cellar consolidated CRD, 2026-09-25]

5. Purchases through Apple or Google

5.1 Apple: Apple handles refunds for App Store purchases. We cannot issue refunds for Apple purchases. Request a refund at https://reportaproblem.apple.com.

5.2 Google Play: you can ask Google Play for a refund. You can also ask us at [email protected]; we apply Section 3 to Google Play subscriptions [OPEN: or state the rule for the Google channel] and issue approved refunds through Google Play [VERIFY: Google Play Help 15574908, 15574897 — EV-232].

5A. Activation Codes bought from a reseller

[OPEN — POL-RTOS-001 §0: keep only if a reseller program is launched] An Activation Code gives Premium for a fixed period and does not renew, so there is nothing to cancel. Refunds and any statutory withdrawal right for a code are handled by the reseller that sold it. If we deactivate a code because the reseller broke its agreement with us, contact [email protected] [COUNSEL: remedy — POL-RTOS-001 §4.3].

6. Cryptocurrency purchases

[OPEN — BRF-2026-001 D7: keep only if cryptocurrency payments are offered] Cryptocurrency purchases are one-time prepayments and do not renew automatically. Refunds, where available under this policy, are paid to a wallet address you control, in [OPEN: the same asset / USDC], for [OPEN: the U.S. dollar value of your original payment / the amount of cryptocurrency received], less network fees. For withdrawals under Section 4, we pay the network fees and refund in the same asset unless you agree otherwise. We do not send refunds to third parties. Blockchain payments cannot be reversed. [COUNSEL: sanctions screening before any refund; money-transmission review before launch]

7. Chargebacks

If you think you were charged incorrectly, please contact us first so we can try to resolve it. This does not affect your right to dispute a charge with your bank or card issuer.

8. Contact and complaints

HidzoVPN, Inc. · [email protected] · Legal Information page: [OPEN: https://hidzovpn.com/legal] [OPEN: state a response time only if support can meet it] [OPEN: link to a complaints procedure — Payments Rulebook §5.6]

Part C — Drafting notes (internal)

C.1 Legal basis

C.2 Operational commitments that must exist before publication

Web cancellation page; EU/UK withdrawal function (two-step, with acknowledgement on a durable medium — reported requirement); trial confirmation email; refund processing within the stated time; logging of consent and cancellation events for dispute evidence (Payments Rulebook §6.2).

C.3 Consistency

Terms §§10–13; checkout disclosure (Rulebook §5.3); store listings; marketing ("cancel anytime"); POL-ID-001 contacts.

C.3a Additional internal items (from full review)

Annual reminder for monthly plans (Cal. Bus. & Prof. Code §17602(h)(1)) — in ToS §11.3; refund currency, exchange rate and tax treatment [OPEN]; Apple consumption data shared in response to refund requests [COUNSEL: privacy / no-logs consistency]; sanctions screening before any refund [COUNSEL]; EU Digital Content Directive conformity remedies alongside the service-failure credit [COUNSEL].

C.4 Limits of this analysis

Verified first-hand: none of the refund-specific law in this cycle. Reported: all items in C.1. Not reviewed: consumer law of other countries where the Services are marketed (Turkey, Indonesia, Saudi Arabia, UAE and others); card-network rules beyond the Rulebook summary. Counsel required: U.S. consumer; EU/UK consumer.

C.5 Review log