Refund Policy

This Refund Policy applies to all MINOMO wallet top-ups made by merchants, City Agents and other operators with access to paid features, through their respective MINOMO management panels. MINOMO is free for citizens, who make no purchases. Together with the Terms of Service and the Privacy Policy, it forms an integral part of the contract with AVi Kairos Srl.

1. MINOMO's payment model

MINOMO is a free service for residents. Merchants, City Agents, and other roles that access paid features operate through a prepaid wallet denominated in euros, which may be topped up at will.

Wallet top-ups can be made in two ways: by card via Paddle.com Market Ltd, acting as Merchant of Record on behalf of AVi Kairos Srl (Paddle handles collection, receipts, EU VAT and any monetary refunds to the original payment method; AVi Kairos Srl is the underlying merchant), or by SEPA bank transfer to AVi Kairos Srl's account, in which case AVi Kairos Srl collects and invoices directly in accordance with Romanian tax law. In both cases service delivery and wallet balance management are AVi Kairos Srl's responsibility.

All paid features on MINOMO — sending push notifications, activating discovery boost addons, loyalty campaigns, advanced MINA features, operational tools for City Agents — are deducted from the wallet balance at the time of activation, at the prices shown prior to confirmation. There are no recurring subscriptions, no monthly or annual plans, and no free trials that auto-convert to paid plans.

2. Refund of remaining balance

The wallet balance you have not yet consumed is always refundable on request, subject to the security checks described in section 5.

• The refund is made to the original payment method used for the top-up: via Paddle for card top-ups, or by bank transfer to the originating IBAN for SEPA top-ups.
• Processing times are normally 5 business days for our approval and a further 3–10 business days for the credit to appear on your payment instrument, depending on your bank or payment provider's timescales. In any event, we complete the steps within our remit within 14 days of receiving the request.
• Refunding the remaining balance does not incur penalties or deductions, except for any fees applied by your payment provider (outside our control).
• If you have made multiple top-ups, we may refund them separately to their respective payment methods for security and anti-fraud reasons.

Account closure (at your initiative or by our reasoned decision, as described in the Terms of Service) automatically triggers the refund procedure for the remaining balance, subject to the cases in section 6.

3. Services already rendered: what is refundable and what is not

Activations of services paid for by drawing on the wallet are delivered digital services: once rendered, they are not refundable, except as required by law (see section 4 for the consumer right of withdrawal and section 6 for malfunctions).

4. Right of Withdrawal (EU consumers)

MINOMO's paid features are aimed at parties acting in the course of a business, trade, craft or profession — including freelancers, sole proprietors and PFAs who top up the wallet for their activity. For these parties the consumer right of withdrawal does not apply.

The provisions of this section therefore apply only to consumers, meaning natural persons who — exceptionally — top up the wallet for purposes outside any trade, business, craft or profession. It replicates and specifies what is already provided in section 8 of the Terms of Service.

4.1 The 14-day period

Pursuant to Directive 2011/83/EU (implemented in Romania by OUG 34/2014 and in Italy by D.Lgs. 206/2005 (Italian Consumer Code)), if you are a consumer you have the right to withdraw from the wallet top-up within 14 calendar days of payment, without having to provide any reason and without penalty.

4.2 Exception for digital services already performed

These two confirmations are requested of you at checkout in a clear manner. If you do not give them, the right of withdrawal remains intact for the entire top-up until the 14th day.

4.3 How to exercise it

To exercise the right of withdrawal, communicate your decision to us by means of an unequivocal statement (preferably by email to [email protected]) within 14 days of payment. No prescribed form is required, but you may use the model statement below if you find it helpful:

4.4 Effects of withdrawal

If you validly exercise the right of withdrawal, we will refund you:

• the portion of credit you have not yet consumed, in all cases;
• the entire top-up, if you have never activated any paid feature from the wallet within the withdrawal period and have not given the two confirmations referred to in section 4.2.

The refund will be made within 14 days of receipt of the withdrawal notice, to the original payment method, with no charge to you for the refund.

5. Request verification and anti-fraud

To protect our users from misuse of their accounts and to deter fraudulent behaviour, we apply proportionate checks to refund requests:

• we verify that the request originates from the email address associated with the account;
• for refund requests that are anomalous relative to the account's historical behaviour, we may request additional documentation (e.g. screenshots of unauthorised activity, a declaration of lost credentials);
• where we detect signals of abusive chargebacks, accumulation of refunds for speculative purposes, or breach of Community Standards, we may temporarily suspend the refund and request clarification;
• in confirmed cases of fraud, chargeback abuse, or serious breach of the Terms, we may refuse the refund within the limits permitted by law and proceed with account closure (see Terms §15).

6. Non-conforming services or malfunctions

Independently of the right of withdrawal, if a paid feature activated from your wallet does not function as intended or is not effectively delivered for reasons attributable to us, you are entitled to:

1. ask us to deliver the service again, where possible;
2. request a credit back to the wallet of the portion corresponding to the service not delivered;
3. in cases of substantial impossibility, request a monetary refund to the original payment card.

For consumers in particular, the rights provided by D.Lgs. 173/2021 (Italian implementation of Directive (EU) 2019/770 on digital content and digital services) and the corresponding Romanian legislation apply: conformity guarantee for the service, right to remedy, price reduction, or termination of contract in the cases provided for.

To report a malfunction, write to [email protected] with: a description of the incident, time and date, any screenshots, and the transaction ID involved. We will respond within 5 business days with an assessment and a remedy plan.

7. Disputes, chargebacks, and coordination with Paddle

We ask you, in our mutual interest, to contact us before opening a dispute or a chargeback with your payment provider. Almost all reasonable refund requests are resolved directly, more quickly than the bank dispute process.

If you nonetheless decide to open a chargeback:

• please be aware that the process is managed by the payment network and by Paddle: we provide Paddle with the documentation necessary to assess the position, but the final decision rests with the network;
• chargebacks filed without prior contact with us may be deemed abusive and may result in account suspension;
• if the chargeback is rejected by the network as unfounded, the account remains subject to possible proportionate measures provided for in the Terms of Service.

Paddle's refund policy in its capacity as Merchant of Record is available at paddle.com/legal/checkout-buyer-terms and applies in coordination with this Policy.

8. If you are not satisfied with our response

If you are not satisfied with our assessment of a refund request, you may contact:

• ANPC — Autoritatea Națională pentru Protecția Consumatorilor (National Authority for Consumer Protection, Romania): anpc.ro
• SAL — Alternative Dispute Resolution (Romania): anpc.ro/ce-este-sal/
• EU ODR Platform: ec.europa.eu/consumers/odr
• the consumer conciliation body in your country of habitual residence, where available.

Your rights to bring proceedings before the court of your country of habitual residence under Regulation (EU) 1215/2012 (Brussels I bis), Arts. 17–19, and the application of the mandatory consumer-protection rules of the law of your country of habitual residence under Regulation (EU) 593/2008 (Rome I), Art. 6, are likewise preserved.

9. Changes to this Policy

We may update this Refund Policy from time to time. When we do so, we update the version and the date; if the change is material, we will notify you proactively with at least 30 days' notice by email and via an in-app notice. For wallet top-ups already made, the version of the Policy in force at the time of payment applies.

10. Change log

11. Contact

• Refund requests and support: [email protected]
• Formal legal correspondence: [email protected]
• General enquiries: [email protected]
• Postal address: AVi Kairos Srl — Strada Lungă 188, Corp C2, Ap. 2, Brașov 500051, România