Refund Policy

Effective Date: February 24, 2026 Last Updated: February 24, 2026 Version: 2.0 Previous Version: 1.0 (January 11, 2025)

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Company Information

Legal Entity: CMG FRAMEWORKS SRL Company Type: SRL (Societate cu Răspundere Limitată) — Limited Liability Company Registered Address: Drumul NISIPOASA, Nr. 46-52, Lot 1/2, Bl. C, Scara C7, Etaj P, Ap. 3, București, Romania Contact Phone: +40 772 125 155 Email: support@cmgworkflow.com Alternative Email: contact@cmgworkflow.com Refund Requests: support@cmgworkflow.com

Company Registration:

• Governed by Romanian Law No. 31/1990 on Companies (Legea nr. 31/1990 privind societățile)
• Consumer protection under OUG 34/2014 (transposing EU Consumer Rights Directive 2011/83/EU)
• General consumer protection under OG 21/1992 (Ordonanța Guvernului nr. 21/1992 privind protecția consumatorilor)
• Digital content and services under OUG 141/2021 (transposing EU Directive 2019/770)
• Payment processor: Stripe, Inc.

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1. Introduction and Scope

This Refund Policy ("Policy") governs all refund, cancellation, billing dispute, and payment reversal requests for services provided by CMG FRAMEWORKS SRL ("we," "us," "our," or the "Company") through the CMG Workflow platform accessible at cmgworkflow.com (the "Service").

This Policy forms part of, and is incorporated by reference into, our Terms of Service. In the event of a conflict between this Policy and the Terms of Service, this Policy shall prevail with respect to refund and cancellation matters.

1.1 Applicable Services

This Policy applies to:

| Service Type | Description | Billing Model | |---|---|---| | Monthly Subscriptions | Recurring monthly billing (Starter, Professional, Enterprise) | Monthly recurring | | Annual Subscriptions | 12-month prepaid plans with discounted pricing | Annual prepaid | | Add-on Modules | Optional features (Lead Management, AI Automation, WhatsApp Integration, Client Management) | Per-module monthly or annual | | Usage-Based Billing | WhatsApp messages, AI conversation tokens, additional storage | Metered (arrears) | | Enterprise/Custom Plans | Bespoke pricing and terms negotiated individually | Per agreement |

1.2 Consumer Rights Under Romanian and EU Law

IMPORTANT FOR CONSUMERS: If you are a consumer — a natural person (individual) acting for purposes outside your trade, business, craft, or profession — you benefit from mandatory consumer protection rights under Romanian and European Union law, including but not limited to:

• 14-Day Right of Withdrawal — Right to cancel distance contracts within 14 calendar days without giving any reason (OUG 34/2014, Art. 9; EU Directive 2011/83/EU, Art. 9)
• Pre-Contractual Information — Right to receive complete pricing, characteristics, and terms before purchase (OUG 34/2014, Art. 4-6)
• Refund Within 14 Days of Withdrawal — If the withdrawal right is exercised, refund within 14 days of receiving the cancellation notice (OUG 34/2014, Art. 18)
• Protection Against Unfair Terms — Contract terms that create a significant imbalance to the detriment of the consumer are unenforceable (Law 193/2000 on Unfair Terms)
• Right to Complain to ANPC — File complaints with the Autoritatea Națională pentru Protecția Consumatorilor (OG 21/1992)
• Alternative Dispute Resolution — Access to SAL (Soluționarea Alternativă a Litigiilor) through ANPC and EU ADR mechanisms

NOTE: Where Romanian or EU law provides greater protection than this Policy, the law prevails. Nothing in this Policy limits or restricts your statutory rights as a consumer.

1.3 Business (B2B) Customers

For business customers — organizations, companies, sole traders, or professionals purchasing for commercial or professional purposes — refunds are governed exclusively by this Policy and the Terms of Service. The statutory right of withdrawal under OUG 34/2014 does not apply to B2B transactions. Enterprise and custom plan customers should additionally refer to Section 12 below.

1.4 Currency

All amounts in this Policy are expressed and processed in Euros (EUR). If you paid in a different currency, refund amounts will be calculated in EUR and converted at the exchange rate applied by Stripe at the time of the refund. We refund the exact amount originally charged in your billing currency, regardless of exchange rate fluctuations.

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2. Right of Withdrawal (14-Day Cooling-Off Period)

2.1 Statutory Right Under OUG 34/2014 and EU Directive 2011/83/EU

Under Ordonanța de Urgență nr. 34/2014 (transposing EU Consumer Rights Directive 2011/83/EU), consumers purchasing services through distance contracts (online) have the right to withdraw from the contract within 14 calendar days from the date the contract is concluded, without giving any reason and without incurring any costs other than those expressly provided by law.

Start of Withdrawal Period: The 14-day period begins on the day the contract is concluded (i.e., the date you complete your subscription purchase).

Exception for Digital Services (Art. 16(1)(m) of Directive 2011/83/EU; Art. 16 of OUG 34/2014): The right of withdrawal may be lost if:

1. Performance of the digital service has begun during the withdrawal period;
2. With your prior express consent; AND
3. You acknowledged that you thereby lose your right of withdrawal.

Our Implementation — Consumer-Friendly Approach: We provide a 14-day money-back guarantee (Section 3) that exceeds the statutory withdrawal right. Even if you access and use the Service during the 14-day period, you may still claim a full refund of the subscription fee under our money-back guarantee. This is more generous than the statutory minimum.

2.2 How to Exercise Your Right of Withdrawal

You may exercise your right of withdrawal by sending a clear, unambiguous statement to us before the 14-day period expires. You may use any of the following methods:

By Email: Send to support@cmgworkflow.com with the subject line: "Withdrawal / Retragere — [Your Organization Name]"

By Post: CMG FRAMEWORKS SRL Attention: Billing Department Drumul NISIPOASA, Nr. 46-52, Lot 1/2 Bl. C, Scara C7, Etaj P, Ap. 3 București, Romania

By Using the Model Withdrawal Form: You may, but are not obligated to, use the standard withdrawal form below (based on Annex I(B) of Directive 2011/83/EU).

The withdrawal is deemed exercised in time if the communication is sent before the 14-day period has expired (date of dispatch, not receipt).

2.3 Model Withdrawal Form (Annex I(B) — Directive 2011/83/EU)

Complete and return this form only if you wish to withdraw from the contract.

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To: CMG FRAMEWORKS SRL, Drumul NISIPOASA, Nr. 46-52, Lot 1/2, Bl. C, Scara C7, Etaj P, Ap. 3, București, Romania; Email: support@cmgworkflow.com

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

• Service: CMG Workflow — [Subscription Plan Name]
• Ordered on (*): [Date of subscription purchase]
• Order ID / Stripe Payment ID: [If available]
• Name of consumer(s): ___________________________
• Address of consumer(s): ___________________________
• Email address: ___________________________

Date: ___________________________

Signature of consumer(s): ___________________________ (only if this form is sent on paper)

(*) Delete as appropriate.

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2.4 Effects of Withdrawal

Upon receiving your valid withdrawal notice:

1. Refund Timing: We will refund all payments received from you within 14 days from the day we receive your withdrawal notice (OUG 34/2014, Art. 18).
2. Refund Method: We will use the same payment method you used for the original transaction, unless you expressly agree otherwise. You will not incur any fees as a result of the refund.
3. Service Termination: Your access to the Service will be terminated upon processing the refund, subject to the 72-hour data export grace period (Section 14).
4. Usage-Based Charges: Charges for usage-based services (WhatsApp messages, AI tokens) consumed during the withdrawal period are excluded from the refund, as these represent third-party costs already incurred (see Section 5).

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3. Money-Back Guarantee (First-Time Subscribers)

3.1 14-Day Money-Back Guarantee

In addition to (and exceeding) the statutory right of withdrawal, we offer a 14-day money-back guarantee to first-time subscribers.

Eligibility:

| Criterion | Requirement | |---|---| | Customer Status | First-time subscriber only (first subscription by a new organization/customer) | | Plan Tiers | All plans: Starter, Professional, Enterprise | | Billing Cycle | First billing cycle only (monthly or annual, whichever is purchased first) | | Time Window | Within 14 calendar days from initial subscription activation | | Account Standing | No Terms of Service violations during evaluation period |

What You Receive:

• 100% refund of the subscription fee paid for the first billing cycle
• You may use the Service during the 14-day evaluation period (this is more generous than the statutory right which may be lost upon accessing digital services)

What Happens After Refund:

• Service access is terminated upon refund processing
• 72-hour data export grace period (see Section 14)
• All data permanently deleted after 72 hours per GDPR Article 17 (Right to Erasure)
• Organization account marked as "refunded" (prevents money-back guarantee re-use; see Section 14.2)

3.2 Exclusions from the Money-Back Guarantee

The following charges are excluded from the money-back guarantee refund:

| Charge Type | Reason for Exclusion | |---|---| | WhatsApp messages sent | Third-party cost (Meta charges us per message) — messages delivered in real-time and cannot be reversed | | AI conversation tokens consumed | Third-party cost (Google Cloud AI charges per API call) — computational resources consumed immediately | | Storage overages | Third-party cost (infrastructure provider charges per GB) — allocated resources cannot be returned | | Add-on module purchases | Separate purchases outside base subscription — subject to their own terms |

Legal Justification: These exclusions apply because the charges represent actual costs incurred with third-party service providers (Meta, Google, infrastructure providers) that are non-recoverable by CMG FRAMEWORKS SRL. This is permitted under consumer protection law where the trader has incurred irrecoverable costs at the consumer's express request.

3.3 How to Request a Money-Back Guarantee Refund

Step 1 — Submit Request Email support@cmgworkflow.com within 14 calendar days of activation with:

• Organization name and account email
• Subscription purchase date and Order ID (found in your billing receipt email)
• Statement: "I am requesting a refund under the 14-day money-back guarantee"
• (Optional) Feedback on why the Service did not meet your needs

Step 2 — Data Export (48-Hour Window) We provide a 48-hour window to export your data before account termination:

• Leads data (CSV)
• Clients data (CSV)
• Conversation logs (JSON)
• WhatsApp templates and automation rules (JSON)
• Team members, roles, and permissions (CSV)
• Organization settings and integrations (JSON)

Step 3 — Refund Processing

| Stage | Timeline | |---|---| | Acknowledgment | Within 24 hours (automated confirmation) | | Approval | Within 48 hours of request (human review) | | Refund Initiation | Within 24 hours of approval (via Stripe) | | Funds in Account | 5-10 business days (card) / 10-15 business days (bank transfer) |

Step 4 — Account Termination Upon refund processing:

• Service access immediately revoked
• Data retained for 72 hours (export window)
• After 72 hours, all data permanently and irreversibly deleted

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4. Subscription Cancellation and Refunds

4.1 Monthly Subscription Cancellations

How to Cancel: Navigate to Account Settings → Billing → "Cancel Subscription" within the CMG Workflow dashboard. You may also cancel by emailing support@cmgworkflow.com.

Cancellation Terms:

• Access continues until the end of the current billing period (you keep access for the time already paid)
• No prorated refunds for unused days within the current monthly cycle
• Subscription does not renew at the end of the cancelled billing period
• Data retained for 30 days after subscription ends, then permanently deleted unless you export it

Worked Example: | Event | Date | Action | |---|---|---| | Subscribe | January 10 | Monthly plan, €50/month activated | | Cancel | January 25 | Cancellation submitted | | Access Ends | February 10 | End of paid billing cycle — no renewal charge | | Data Deleted | March 12 | 30 days after subscription end |

No refund for January 25 to February 10 unused portion. You retain full access until February 10.

Rationale: Monthly pricing already provides pay-as-you-go flexibility. Service resources (database, storage, API quotas) are allocated for the full monthly period regardless of usage patterns.

4.2 Annual Subscription Cancellations and Early Termination

Annual subscriptions (12-month prepaid plans) are eligible for prorated refunds based on the timing of cancellation.

Prorated Refund Formula:

Refund Amount = (Annual Fee Paid) × (Months Remaining / 12) × 0.80

The 20% administrative deduction covers:

• Stripe payment processing fees (non-refundable by Stripe)
• Administrative costs of refund processing
• Discounted annual pricing benefit already received versus monthly equivalent

Eligibility Windows:

| Cancellation Timing | Refund Eligibility | |---|---| | Within first 14 days | Full refund under money-back guarantee (Section 3) or right of withdrawal (Section 2) | | Months 1-6 | Prorated refund with 20% administrative fee | | After month 6 (50% elapsed) | No refund — access continues until end of annual period |

Worked Example 1 — Eligible for Prorated Refund:

| Item | Value | |---|---| | Annual subscription | €500/year (purchased January 1, 2026) | | Cancellation date | April 15, 2026 (3.5 months elapsed) | | Months remaining | 8.5 months | | Calculation | €500 × (8.5 / 12) × 0.80 | | Refund amount | €283.33 | | Effective cost for 3.5 months | €216.67 (€61.91/month — compare to monthly rate) |

Worked Example 2 — NOT Eligible:

| Item | Value | |---|---| | Annual subscription | €500/year (purchased January 1, 2026) | | Cancellation date | August 1, 2026 (7 months elapsed) | | Months remaining | 5 months | | Refund | €0 — past 50% threshold | | Access continues until | December 31, 2026 |

Worked Example 3 — Early Cancellation (Month 2):

| Item | Value | |---|---| | Annual subscription | €840/year (Professional plan, purchased February 1, 2026) | | Cancellation date | March 20, 2026 (1.6 months elapsed) | | Months remaining | 10.4 months | | Calculation | €840 × (10.4 / 12) × 0.80 | | Refund amount | €582.40 | | Effective cost for 1.6 months | €257.60 (€161/month) |

How to Cancel Annual Subscription: Email support@cmgworkflow.com with:

• Organization name and account email
• Annual subscription purchase date and Order ID
• Cancellation reason (optional)
• Whether you wish to export your data before termination

Processing Time:

| Stage | Timeline | |---|---| | Acknowledgment | Within 24 hours | | Refund decision | 3-5 business days | | Refund processing | 7-10 business days from approval | | Total | ~2-3 weeks from request to bank account credit |

4.3 Automatic Renewal and Cancellation

Renewal Reminder System: We send email reminders before automatic renewal:

| Reminder | Timing | |---|---| | First notice | 14 days before renewal | | Second notice | 7 days before renewal | | Final reminder | 24 hours before renewal |

Reminders are sent to the organization admin email and billing contact email.

Refund Eligibility for Automatic Renewals:

| Scenario | Refund? | Details | |---|---|---| | Payment processing error | Yes | Incorrect amount, duplicate charge, technical error | | Cancellation not honored | Yes | You cancelled before renewal but system charged anyway (our error) | | Unauthorized renewal | Yes | Account compromised, payment method used without authorization | | Forgot to cancel | Case-by-case | Goodwill consideration (see Section 10) |

How to Cancel Automatic Renewal:

1. Self-Service: Account Settings → Billing → "Cancel Auto-Renewal"
2. Email: Send cancellation request to support@cmgworkflow.com at least 48 hours before renewal date
3. Confirmation: You will receive email confirmation of cancellation with the date your access will end

4.4 Free Trial to Paid Conversion

If you used a free trial before purchasing a paid subscription:

• Billing starts on the day the trial expires (or earlier if you manually upgrade)
• No double billing — trial period is not charged retroactively
• 14-day money-back guarantee applies from the paid subscription start date, not the trial start date
• If you cancel during the trial, you are not charged anything
• If the trial auto-converts to paid and you did not intend to continue, contact us within 48 hours for a full refund (goodwill)

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5. Usage-Based Billing Exclusions

5.1 Non-Refundable Usage Charges

The following usage-based charges are non-refundable under all circumstances, including when exercising the right of withdrawal or money-back guarantee:

WhatsApp Business API Messages:

• Charge: Per message sent via WhatsApp Business Cloud API
• Third-Party Provider: Meta Platforms, Inc.
• Why Non-Refundable: Messages are delivered to recipients in real-time. Meta charges CMG FRAMEWORKS SRL per message sent; these costs are irrecoverable. Messages cannot be "unsent" or reversed once delivered.
• Your Control: You control message volume through templates, automation rules, manual sends, and budget caps.
• Billing: Charged in arrears (billed after messages sent, typically monthly).

Google Gemini AI Conversation Tokens:

• Charge: Per 1,000 tokens consumed by AI conversations
• Third-Party Provider: Google Cloud (Gemini API)
• Why Non-Refundable: AI processing occurs in real-time; computational resources are consumed immediately and irreversibly. Google charges CMG FRAMEWORKS SRL per API call.
• Your Control: You control AI automation rules, conversation triggers, and token spending limits.
• Billing: Charged in arrears.

Storage Overages:

• Charge: Per GB per month beyond included plan limits
• Third-Party Provider: Infrastructure provider (database and file storage)
• Why Non-Refundable: Storage resources are allocated at infrastructure level; overage costs are passed through from the provider.
• Your Control: Monitor storage in dashboard, delete unused data, or upgrade plan for higher limits.

Stripe Payment Processing Fees:

• Cost: Approximately 2.9% + €0.25 per successful transaction
• Note: When we issue a refund, Stripe retains its original processing fee. We absorb this cost — it is not passed to you.

5.2 Legal Justification for Usage Exclusions

Under Article 16(1)(a) of Directive 2011/83/EU (transposed by OUG 34/2014, Art. 16), the right of withdrawal does not apply to services fully performed where the consumer gave prior express consent and acknowledged the loss of withdrawal right. For usage-based services, each individual message sent or API call made constitutes a fully performed service element at the consumer's express request.

Additionally, under Article 14(3) of Directive 2011/83/EU, when a consumer exercises the right of withdrawal after requesting that performance begin during the withdrawal period, the consumer shall pay an amount proportional to what has been provided until the time of withdrawal. Usage-based charges represent this proportional amount.

5.3 Budget Controls and Cost Transparency

Before Enabling Usage-Based Features:

• WhatsApp message pricing calculator (estimated monthly volume)
• AI conversation token estimator (average tokens per conversation)
• Storage usage monitor (current usage + projected growth)

Budget Caps:

• WhatsApp Message Cap: Stop sending after X messages/month
• AI Token Cap: Disable AI automation after X tokens/month
• Storage Alert: Notification at 80% of plan limit
• Email Alerts: Sent at 50%, 80%, and 100% of budget cap

Real-Time Monitoring:

• Usage dashboard (current month consumption)
• Projected invoice preview (estimated charges for current billing period)
• Historical usage reports (analyze trends, optimize spending)

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6. Service Failure Compensation

6.1 Service Level Commitment

| Metric | Target | |---|---| | Monthly uptime | 99.5% (excluding scheduled maintenance) | | Scheduled maintenance | Announced 48 hours in advance, during 2:00-6:00 AM EET | | Max unscheduled downtime | < 4 hours per month |

6.2 Outage Compensation Formula

If the Service is completely unavailable (returns errors, is inaccessible, or is non-functional) for more than 24 consecutive hours due to our infrastructure failure:

Compensation = (Monthly Subscription Fee / 30) × Days of Outage

Compensation is applied as:

• Automatic credit to next billing cycle (default); OR
• Cash refund to original payment method (upon request)

Worked Example:

| Item | Value | |---|---| | Monthly subscription | €50/month | | Service down | 48 consecutive hours (2 days) | | Calculation | €50 / 30 × 2 | | Compensation | €3.33 |

6.3 What Does NOT Qualify for Outage Compensation

| Exclusion | Reason | |---|---| | Third-party service failures | WhatsApp API outage, Google Gemini API downtime, Supabase database issues — outside our control | | Scheduled maintenance | Announced in advance per SLA | | Your connectivity issues | Service is available but inaccessible due to your internet, device, or local network | | User error | Incorrect configuration, account suspension for Terms violation | | Force majeure | See Section 9 |

6.4 How to Request Outage Compensation

Email support@cmgworkflow.com within 14 days of the outage with:

• Date and time of unavailability (include timezone)
• Description of the error or inaccessibility
• Screenshots or error logs (if available)
• Impact on your business operations

We will investigate using server logs and respond within 5-7 business days with:

• Confirmed duration of outage
• Root cause determination (our infrastructure vs. third-party)
• Eligibility assessment and compensation amount

6.5 Partial Service Failures (Service Degradation)

If the Service is partially available (degraded performance, specific features unavailable) for more than 7 consecutive days due to our infrastructure issues:

Credit = (Monthly Subscription Fee / 30) × Days Degraded × Severity Factor

Severity Factors:

| Severity | Description | Factor | Example | |---|---|---|---| | Critical | Core feature completely unusable | 0.50 (50%) | Leads Kanban not loading, WhatsApp integration down | | Major | Significant performance impact | 0.30 (30%) | Pages loading > 10 seconds, search not returning results | | Minor | Non-core features affected | 0.10 (10%) | Cosmetic issues, reports delayed, non-essential integrations |

Worked Example — Critical Degradation:

| Item | Value | |---|---| | Monthly subscription | €70/month (Professional plan) | | Issue | Leads Kanban board not loading for 10 days | | Severity | Critical (0.50) | | Calculation | €70 / 30 × 10 × 0.50 | | Credit | €11.67 |

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7. Data Loss Compensation

7.1 Our Data Protection Commitment

| Measure | Detail | |---|---| | Daily backups | Full database backup every 24 hours | | Point-in-time recovery | Restore to any point within last 7 days | | Redundant storage | Data replicated across 3 availability zones | | Data durability | 99.99% (PostgreSQL with automated backups) |

7.2 Compensation for Data Loss Due to Our Negligence

If your organization's data is permanently lost or corrupted due to our negligence or system failure (not your actions or third-party integration failures):

| Compensation | Details | |---|---| | Full refund | Most recent billing cycle (monthly or prorated annual) | | Data recovery costs | We cover reasonable costs of recreating lost data, up to 3× monthly subscription fee | | Service credit | 3 months free service (if you choose to continue) |

7.3 What Does NOT Qualify

• User-initiated deletion (you or your team members deleted data)
• Failure to request backup restoration within the 7-day retention window
• Third-party integration failures (WhatsApp API, external CRM sync)
• Account termination data deletion per retention policy

7.4 Data Loss Prevention — Your Responsibilities

• Export data regularly using the built-in CSV/JSON export
• Restrict delete permissions to admin users only
• Contact us immediately (within 7 days) if you notice missing data
• Maintain local backups of critical information

7.5 How to Report Data Loss

Email support@cmgworkflow.com immediately with:

• Date/time you noticed data missing
• Description of missing data (leads, clients, conversations, etc.)
• Last known time data was present
• Any recent actions (imports, deletions, integrations) that may be related

Response Time: Data restoration prioritized (within 24 hours); refund decision within 7 business days.

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8. Chargebacks and Payment Disputes

8.1 Preferred Dispute Resolution: Contact Us First

If you believe a charge is incorrect, please contact us before initiating a chargeback with your bank. We resolve 95% of billing disputes within 48 hours.

Proper Dispute Process:

1. Email support@cmgworkflow.com with: date of charge, amount, reason you believe it is incorrect
2. We review billing records and usage data within 48 hours
3. If the charge was an error: immediate refund
4. If the charge was correct: clear explanation with supporting documentation

8.2 Chargeback Consequences

A chargeback (disputing a charge directly with your bank or credit card company, bypassing our refund process) triggers the following consequences:

Immediate:

• Account suspended — Service access revoked pending investigation
• Chargeback fee of €15-25 charged by Stripe

Investigation (30-90 days): We provide evidence to the bank, including purchase records, Terms acceptance logs, and service access data.

Outcome — Chargeback Reversed (Bank Sides with Us):

• Original charge reinstated + chargeback fee (€15-25) owed by you
• Account remains suspended until full payment received
• Collections proceedings may be initiated for unpaid amounts

Outcome — Chargeback Upheld (Bank Sides with You):

• You retain the refunded amount
• Account permanently closed
• Permanent ban from future Service use (fraud prevention measure)
• Usage-based charges incurred remain your liability

8.3 When a Chargeback May Be Appropriate

We acknowledge that chargebacks exist as a consumer protection mechanism. A chargeback may be appropriate if:

• You contacted us and received no response within 7 business days
• We refused to refund a clearly erroneous charge (duplicate charge, wrong amount)
• Unauthorized use — you did not authorize the subscription (account compromised, stolen payment method)
• Fraud — your payment method was used without your knowledge or consent

8.4 Fraud Prevention

Detection methods: Multiple chargebacks from same entity, signup-then-chargeback pattern, stolen payment methods, multiple accounts after previous chargeback.

Consequences for Fraudulent Activity:

• Permanent ban from Service (all associated email addresses)
• Report to Stripe Radar (shared fraud database)
• Legal action for amounts exceeding €500 (Romanian Criminal Code, Art. 244 — fraud; Art. 249 — computer fraud)
• Cooperation with law enforcement

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9. Force Majeure

9.1 Definition

Force majeure events are unforeseeable and unavoidable circumstances beyond our reasonable control that prevent or significantly impair Service provision, as defined under Article 1351 of the Romanian Civil Code (Codul Civil).

9.2 Specific Examples

• Natural disasters: earthquakes, floods, fires, volcanic eruptions, extreme weather events affecting data centers
• Armed conflict: war, terrorism, civil unrest, military action
• Government actions: internet shutdowns, service bans, data center seizures, sanctions, emergency legislation
• Infrastructure failures: submarine cable cuts, DNS root server failures, internet backbone outages, major cloud provider failures
• Pandemics: declared public health emergencies affecting workforce and service delivery
• Cyberattacks: DDoS attacks, ransomware, or state-sponsored cyber incidents of unprecedented scale
• Energy disruptions: widespread power outages, energy rationing affecting data centers

9.3 Refund Policy During Force Majeure

| Duration | Our Obligation | |---|---| | Up to 7 days | No refund; status updates every 4-8 hours | | 7-30 consecutive days | Prorated service credit for affected days | | Over 30 consecutive days | Option to suspend subscription (no charges) OR cancel with prorated refund |

Communication During Force Majeure:

• Status updates every 4-8 hours
• Email notifications to all subscribers
• Estimated restoration timeline (when available)

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10. Goodwill Refunds and Discretionary Credits

10.1 Discretionary Refund Policy

While this Policy defines strict eligibility criteria, we value customer satisfaction and may, at our sole discretion, offer goodwill refunds in exceptional circumstances not covered by standard policy provisions.

Examples where goodwill refunds may be considered:

• Personal hardship (medical emergency, family bereavement, business closure due to economic conditions)
• Miscommunication about Service capabilities during sales or onboarding
• Technical issues that significantly impaired (but did not completely prevent) Service use
• First-time automatic renewal where customer genuinely forgot to cancel

10.2 How to Request

Email support@cmgworkflow.com with:

• Explanation of circumstances
• Why the situation is exceptional
• Supporting documentation (if applicable)
• Requested resolution (full refund, partial refund, service credit)

Review: Case-by-case evaluation within 5-7 business days. Decision considers customer history, business impact, and circumstances.

Important:

• Goodwill refunds are exceptions, not entitlements
• One approval does not create a precedent for future requests
• Repeated goodwill requests or dishonest claims may result in account review

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11. Billing Dispute Resolution

11.1 Formal Dispute Process and Timelines

| Stage | Timeline | Action | |---|---|---| | Acknowledgment | Within 48 hours | Written confirmation that we received your dispute | | Investigation | Within 7 business days | Review billing records, usage data, and service logs | | Resolution | Within 14 business days | Final decision with detailed explanation | | Escalation | Within 5 business days | Senior billing manager reviews if you disagree with initial decision |

11.2 How to File a Billing Dispute

Email support@cmgworkflow.com with subject line: "Billing Dispute — [Organization Name] — [Invoice/Payment ID]"

Include:

• Date(s) and amount(s) in dispute
• Reason for dispute (incorrect charge, unauthorized charge, service not provided, etc.)
• Supporting evidence (screenshots, bank statements, communication records)
• Requested resolution

11.3 If We Cannot Resolve the Dispute

If our internal dispute resolution process does not resolve the matter to your satisfaction, you may:

1. Escalate to ANPC (see Section 13)
2. Use SAL alternative dispute resolution (see Section 13)
3. Pursue legal action in Romanian courts (see Section 15)

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12. Enterprise and Custom Plan Terms

12.1 Enterprise Plans

Customers on Enterprise or custom-negotiated plans are subject to:

• The terms specified in their individual Enterprise Agreement or Statement of Work (SOW)
• Where the Enterprise Agreement is silent on refunds, this Policy applies as a fallback
• Enterprise plans may include custom SLA terms with higher compensation thresholds

12.2 Custom Pricing

For customers with individually negotiated pricing:

• Prorated refund calculations use the actual amount paid, not published list prices
• Administrative fee percentages may differ per the Enterprise Agreement
• Minimum contract terms (if any) are specified in the Enterprise Agreement

12.3 Enterprise Cancellation

Enterprise customers should contact their designated account manager or email support@cmgworkflow.com for cancellation requests. Minimum notice periods may apply as specified in the Enterprise Agreement.

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13. Romanian Consumer Protection — ANPC Complaint Procedures

13.1 Your Right to Complain

Under OG 21/1992 (Ordonanța Guvernului nr. 21/1992 privind protecția consumatorilor), Romanian consumers have the right to file complaints with the national consumer protection authority if they believe their rights have been violated.

13.2 ANPC Contact Information

Autoritatea Națională pentru Protecția Consumatorilor (ANPC)

• Consumer Hotline: +40 21 9551 (InfoCons)
• Website: https://anpc.ro/
• Online Complaints: https://reclamatii.anpc.gov.ro/
• Address: Bulevardul Aviatorilor nr. 72, Sector 1, 011865 București, Romania
• Email: office@anpc.ro

13.3 How to File an ANPC Complaint

1. Try to resolve directly with us first — Contact support@cmgworkflow.com and allow 14 business days for resolution
2. If unresolved, file a complaint with ANPC:
   • Online at https://reclamatii.anpc.gov.ro/
   • By phone at +40 21 9551
   • In writing to the ANPC address above
3. Include: Your contact details, our company information (CMG FRAMEWORKS SRL), description of the issue, copies of correspondence, and the resolution you seek
4. ANPC processing: Complaints are typically reviewed within 30 days under Romanian law

13.4 SAL — Alternative Dispute Resolution (Soluționarea Alternativă a Litigiilor)

ANPC operates SAL, an alternative dispute resolution (ADR) service that can review national and cross-border consumer disputes:

• Website: https://anpc.ro/categorie/1270/sal
• SAL advisors specialize in alternative dispute resolution
• The process is free for consumers
• Decisions are non-binding but carry administrative weight

13.5 EU Alternative Dispute Resolution

Important Note (February 2026): The European Commission's Online Dispute Resolution (ODR) platform at https://ec.europa.eu/consumers/odr was discontinued on July 20, 2025, pursuant to Regulation (EU) 2025/40.

Under the revised ADR Directive (EU) 2025/2647 (entered into force January 19, 2026), EU consumers retain the right to use alternative dispute resolution for cross-border disputes. Key changes:

• Member States must ensure ADR entities are available for all consumer disputes, including digital services
• The European Commission is developing an interactive consumer information tool (expected April 2026) to guide consumers to appropriate ADR bodies
• Until the new tool is available, consumers may contact their national ADR body (in Romania: SAL through ANPC) or the European Consumer Centre (ECC Romania) for cross-border disputes:
  • ECC Romania: https://eccromania.ro/
  • Email: office@eccromania.ro

We are committed to participating in ADR proceedings where required by law.

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14. Data Export and Account Closure

14.1 Data Export Grace Period

Upon any refund-related account termination:

| Period | Status | |---|---| | 0-48 hours | Active export window — login and download your data | | 48-72 hours | Extended grace period — contact support if you need more time | | After 72 hours | All data permanently and irreversibly deleted per GDPR Article 17 |

Available Export Formats:

| Data Type | Format | |---|---| | Leads | CSV (name, phone, email, status, custom fields, timestamps) | | Clients | CSV (contact info, company details, address, relationship data) | | Conversations | JSON (message logs, WhatsApp conversations, AI responses) | | Templates | JSON (WhatsApp message templates, automation rules) | | Team Members | CSV (users, roles, permissions) | | Settings | JSON (organization settings, branding, integrations) |

Export Process:

1. Login to dashboard → Settings → Data Export → "Export All Data"
2. Download ZIP file containing all CSVs and JSONs
3. Confirm export complete → We proceed with account termination

Your right to data portability under GDPR Article 20 is upheld regardless of the reason for account closure.

14.2 Account Reactivation After Refund

| Refund Type | Reactivation | New Account | Data Recovery | Cooling-Off | |---|---|---|---|---| | 14-day money-back | Not available | Yes (new customer) | No | 12 months before new guarantee eligibility | | Annual prorated | Immediately available | N/A | No — data already deleted | N/A | | Withdrawal right | Not available | Yes | No | 12 months before new guarantee eligibility |

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15. Refund Payment Timelines and Methods

15.1 Payment Method Refund Timelines

| Payment Method | Refund Timeline | Notes | |---|---|---| | Credit/debit card | 5-10 business days | Stripe initiates immediately; bank processing time varies | | Bank transfer (SEPA) | 10-15 business days | Longer processing due to interbank settlement | | Expired/closed card | 10-20 business days | Funds routed through card network to issuing bank |

All refunds are processed to the original payment method used for the purchase (Stripe requirement). If your original payment method is no longer available, contact us to arrange alternative refund delivery.

15.2 Tax and VAT Handling

• Refunds include any VAT (TVA) charged on the original transaction
• If a VAT invoice was issued, a credit note will be generated and sent to your billing email
• For Romanian-registered businesses that reclaimed input VAT: you may need to adjust your VAT return for the period in which the credit note is issued
• Enterprise customers with custom invoicing should contact their account manager for tax documentation

15.3 Partial Refund Calculations

For prorated or adjusted refunds, a transparent breakdown will be included in the approval email. Example:

Annual fee paid:           €500.00
Usage charges (non-refundable):  - €45.00  (WhatsApp: €30, AI tokens: €15)
Administrative fee (20%):  - €91.00  (20% of €455 eligible amount)
─────────────────────────────────────
Refund amount:             €364.00

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16. Non-Refundable Scenarios

16.1 Terms of Service Violations

No refunds are available if your account is suspended or terminated due to violations of our Terms of Service, including but not limited to:

• WhatsApp policy violations: Spam, unsolicited marketing, quality rating dropped to Red (>10% block rate), Meta policy violations
• Prohibited content: Illegal, harmful, or fraudulent messages; intellectual property violations; harassment
• Platform abuse: Multiple accounts to circumvent limitations, reverse engineering, billing evasion, exploiting vulnerabilities
• Payment fraud: Chargebacks on legitimate charges, stolen payment methods, false billing information

16.2 Third-Party Service Restrictions

No refunds if you cannot use the Service due to third-party restrictions outside our control:

• Meta rejects your WhatsApp Business Verification
• Meta suspends your WhatsApp Business Account
• Your WhatsApp quality rating drops to Red (Meta restriction)
• Third-party API policy changes making your use case non-compliant

Mitigation: We provide pre-signup eligibility checks, quality rating monitoring, and best practices documentation.

16.3 Change of Mind (After Guarantee Period)

After the 14-day money-back guarantee / withdrawal period:

• "We decided to use a different CRM" — No refund (use cancellation process)
• "We're shutting down our business" — No refund (cancel to stop future charges)
• "We're not using it enough" — No refund (cancel to prevent renewal)
• "It's too expensive" — No refund (downgrade before renewal)

16.4 Feature Deprecation and Product Changes

No refunds for:

• Feature deprecation (30-day advance notice provided)
• Requested features not added to roadmap
• Product changes you disagree with (UI redesign, workflow changes)

Your Rights:

• Cancel before next renewal if dissatisfied
• Export all data before cancellation
• No retroactive price increases — price locked for current subscription period
• 30-day notice of material feature changes
• 60-day notice of material changes to refund rights — option to cancel before effective date

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17. Governing Law and Jurisdiction

17.1 Applicable Law

This Policy is governed by and construed in accordance with the laws of Romania, including but not limited to:

• Romanian Civil Code (Codul Civil — Law 287/2009)
• Law No. 31/1990 on Companies (Legea nr. 31/1990 privind societățile)
• OUG 34/2014 on consumer rights in distance and off-premises contracts
• OG 21/1992 on consumer protection
• OUG 141/2021 on digital content and digital services
• Law 193/2000 on unfair terms in consumer contracts
• EU Consumer Rights Directive 2011/83/EU (as amended by Directive (EU) 2023/2673)
• EU ADR Directive (EU) 2025/2647

17.2 Jurisdiction

Any disputes arising from this Policy shall be resolved:

1. First: Through our internal dispute resolution process (Section 11)
2. Second: Through ANPC complaint or SAL alternative dispute resolution (Section 13)
3. Third: Before the competent courts of București, Romania

For cross-border consumer disputes within the EU, the consumer may also bring proceedings in the courts of their Member State of domicile, pursuant to Regulation (EU) No. 1215/2012 (Brussels I Recast).

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18. Changes to This Policy

18.1 Policy Updates

We may update this Policy to reflect:

• Changes in Romanian or EU consumer protection law
• Changes in Stripe refund policies
• Changes in third-party service costs
• Business model or subscription tier changes
• Clarifications based on customer inquiries or disputes

18.2 Notice Requirements

| Type of Change | Notice Period | Effective Date | |---|---|---| | Non-material (clarifications, formatting) | Posted on website | Immediately | | Material (refund terms, eligibility criteria) | 30 days advance email notice | After notice period for new subscriptions; at next renewal for existing | | Rights-reducing (eliminating or reducing refund rights) | 60 days advance email notice | Option to cancel before effective date |

Grandfathering: Active subscriptions are governed by the Policy version in effect at the time of purchase, for the duration of the current subscription period.

18.3 Version History

| Version | Effective Date | Summary | |---|---|---| | 1.0 | January 11, 2025 | Initial version | | 2.0 | February 24, 2026 | Comprehensive rewrite: added withdrawal form template, updated ODR/ADR references, expanded worked examples, added enterprise terms, billing dispute timelines, tax handling, partial service refund formula, force majeure details |

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19. Definitions

| Term | Definition | |---|---| | Annual Subscription | 12-month prepaid subscription with discounted pricing versus monthly equivalent | | Business Day | Monday through Friday, excluding Romanian public holidays and December 25-January 1 | | Chargeback | Dispute initiated with bank/credit card company to reverse a payment, bypassing merchant's refund process | | Consumer | Natural person (individual) acting for purposes outside their trade, business, craft, or profession (as defined by OUG 34/2014 and OG 21/1992) | | Force Majeure | Unforeseeable and unavoidable circumstances beyond reasonable control preventing contract performance (Art. 1351 Romanian Civil Code) | | Goodwill Refund | Discretionary refund granted outside standard policy terms at Company's sole discretion | | Monthly Subscription | Recurring subscription billed every calendar month | | Money-Back Guarantee | 14-day full refund for first-time subscribers (Section 3) | | Organization | Business entity subscribing to the Service (equivalent to "tenant" in multi-tenant architecture) | | Prorated Refund | Partial refund calculated proportionally based on unused service period | | Right of Withdrawal | Statutory 14-day right to cancel distance contracts without reason (OUG 34/2014, Art. 9) | | Service | CMG Workflow platform including all features, accessible at cmgworkflow.com | | Service Credit | Account credit applied to future billing cycle as alternative to cash refund | | Service Degradation | Partial service availability with reduced performance or functionality | | Usage-Based Charges | Variable costs based on consumption: WhatsApp messages, AI tokens, storage overages | | Withdrawal Period | 14 calendar days from contract conclusion during which the consumer may exercise the right of withdrawal |

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20. Acceptance of This Policy

By subscribing to the CMG Workflow Service, you acknowledge that you have:

• Read and understood this Refund Policy
• Understood refund eligibility criteria and non-refundable scenarios
• Understood that usage-based charges (WhatsApp messages, AI tokens) are non-refundable due to third-party costs
• Understood the 14-day money-back guarantee terms and its limitations
• Understood annual subscription prorated refund calculations
• Understood your right of withdrawal under OUG 34/2014 and the conditions under which it may be waived
• Been informed of ANPC complaint procedures and alternative dispute resolution options
• Agreed to contact us before initiating chargebacks
• Agreed to export your data before account closure (data cannot be recovered after deletion)

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21. Contact Information

21.1 Refund and Billing Inquiries

| Channel | Details | Response Time | |---|---|---| | Email (Recommended) | support@cmgworkflow.com | 24-48 hours (business days) | | Alternative Email | contact@cmgworkflow.com | 24-48 hours | | Phone | +40 772 125 155 | Mon-Fri, 9:00-17:00 EET (urgent billing issues only) | | Post | CMG FRAMEWORKS SRL, Drumul NISIPOASA, Nr. 46-52, Lot 1/2, Bl. C, Scara C7, Etaj P, Ap. 3, București, Romania | 5-7 business days |

21.2 Legal and Compliance

| Purpose | Contact | |---|---| | Legal notices | contact@cmgworkflow.com | | GDPR / data protection requests | support@cmgworkflow.com | | ANPC complaints | contact@cmgworkflow.com |

21.3 Escalation Path

If you do not receive a response within stated timeframes:

1. Reply to your original email with "ESCALATION REQUEST" in the subject line
2. Escalated requests are reviewed within 24 hours by a senior billing manager
3. If still unresolved after 7 business days, contact ANPC (see Section 13)

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CMG FRAMEWORKS SRL București, Romania Effective: February 24, 2026

This Refund Policy was last reviewed and updated on February 24, 2026. For questions, contact support@cmgworkflow.com or call +40 772 125 155.