Version 1.0 — Effective 2026-04-21
This policy sets out the terms under which Witness refunds payments for its services. It applies to all purchases made through Paddle, our Merchant of Record, and incorporates the consumer rights granted under the EU Distance Selling Directive (Directive 2011/83/EU).
This policy applies to all Witness tiers — Starter, Professional, and Team — and to the associated annual compliance maintenance fees, purchased through the Witness website via Paddle as Merchant of Record. It does not apply to services rendered by third parties outside the Witness platform (for example, notified-body assessments or independent legal counsel).
If you purchased Witness as a consumer (a natural person acting outside their trade, business, or profession), you have the right to withdraw from the contract within fourteen (14) days of the purchase date without giving any reason, in accordance with Article 9 of Directive 2011/83/EU. Upon valid withdrawal, Witness will refund all payments received from you, including standard delivery costs, within fourteen (14) days using the same payment method used for the original transaction. To exercise your right of withdrawal, email support@witness-compliance.eu with your order ID and a clear statement that you wish to withdraw. You may use the model withdrawal form contained in Annex I(B) of Directive 2011/83/EU, but this is not mandatory.
Immediate performance and loss of the right of withdrawal (Art. 16(m) Directive 2011/83/EU)
Witness supplies digital content that is not delivered on a tangible medium. By clicking "Start compliance" or completing checkout for a paid tier, you expressly consent to Witness beginning performance immediately and you expressly acknowledge that you thereby lose your right of withdrawal under Article 16(m) of Directive 2011/83/EU as soon as performance has begun. Performance is deemed to have begun at the earlier of: (i) the moment the first compliance document (e.g. Annex IV technical file, Article 9 risk management record, Article 27 fundamental rights impact assessment, or AI literacy record) is generated using your account; or (ii) the moment you first use your account to access any paid feature that is not available on the free tier. Until that point, the 14-day consumer right of withdrawal described above remains available.
If you purchased Witness as a business (legal entity, sole trader, or other organisation acting within its trade or profession), the statutory right of withdrawal does not apply. As a goodwill gesture, Witness offers a refund of the initial tier fee within fourteen (14) days of purchase, provided the service has not been "substantially used". "Substantially used" means: more than three (3) compliance documents (e.g. Annex IV technical file, Article 9 risk management record, Article 27 FRIA, AI literacy record) have been generated, exported, or shared; or a certificate or conformity attestation has been issued on the basis of the subscription. After the fourteen-day window, or where the service has been substantially used, business purchases are non-refundable.
Annual compliance maintenance is charged once per year to keep your account in monitoring mode, to generate updated compliance artifacts when the underlying regulation changes, and to retain access to AI-assisted features and alerting. If you cancel within thirty (30) days of a renewal of your annual maintenance, Witness will issue a pro-rated refund for the unused portion of the twelve-month period, calculated on a daily basis. Cancellations after the first thirty days of a renewal period do not qualify for a refund, but the annual maintenance will simply not renew the following year. First-year maintenance is included in the initial tier fee and is not separately refundable.
Send an email to support@witness-compliance.eu from the email address associated with your account, including: (a) your order ID (visible in the Paddle receipt you received by email); (b) a brief indication of which refund ground you are invoking (14-day consumer withdrawal, 14-day business goodwill, or annual-maintenance pro-rated); and (c) for business purchases, a statement that the service has not been substantially used. No justification is required for consumer withdrawals within the 14-day window.
Approved refunds are processed within ten (10) business days through Paddle back to the original payment method. The time it then takes for the refund to appear on your statement depends on your card issuer or bank and is outside Witness's control.
The following are non-refundable regardless of the above: (a) compliance certificates, conformity attestations, or other work product that has already been issued and delivered to you on the basis of the subscription — these represent performed work that cannot be reclaimed; (b) any third-party costs passed through to you (for example, notified-body fees or external assessor fees) where those amounts have already been paid to the third party; (c) amounts that Witness is required by applicable tax or financial law to retain. These exceptions apply equally to consumers and business customers.
Refund requests, questions about this policy, and complaints about its application should be sent to support@witness-compliance.eu. Witness is not obligated to participate in out-of-court dispute resolution but will consider such requests in good faith.
If we cannot resolve your complaint to your satisfaction, consumers resident in the EU may also make use of the European Commission's Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr.
Questions about this refund policy or a pending request can always be sent to support@witness-compliance.eu. We reply within one business day.