Terms of service.

Part A is effective now. It governs your use of the Service as it exists today: a free beta. The Service has no paid plans and no checkout at the moment, so there are no charges, no auto-renewals, and no payment obligations under Part A.

The subscription terms in Part B (Paddle, billing, auto-renewal, the right of withdrawal, refunds) are forward-looking and not yet active. They take effect only when we launch paid plans and the checkout that supports them, on notice. Until then they bind no one.

These Terms of Service (the “Terms”) form a legally binding agreement between you and Soldato Matthew James, an Italian sole trader (ditta individuale) acting under the trading name “Sparks” (“we”, “us”). The Terms govern your access to and use of sparksesl.com and every feature of the Service.

Our identification details, published in accordance with Art. 7 of D.Lgs. 70/2003 (Italian implementation of the eCommerce Directive 2000/31/EC) and Art. 2250 of the Italian Civil Code:

• Registered name: Soldato Matthew James
• Registered address: Via Torino 2, 20831 Seregno (MB), Italy
• Codice Fiscale: SLDMTH99T02B729X
• Partita IVA / EU VAT: IT13444260965
• General contact: hello@sparksesl.com
• Privacy contact: privacy@sparksesl.com

By creating an account, you confirm that you are at least 18 years old, that you have legal capacity to enter into this contract, and that you accept these Terms and our Privacy Policy.

How your acceptance is captured

Binding clickwrap assent is collected at signup: the create-account form requires you to affirmatively agree to these Terms and the Privacy Policy (with both documents linked) before you can submit, and the timestamp and the version you accepted are logged. If you do not accept these Terms, do not create an account and do not use the Service.

The Service

Sparks is an online library and presentation tool for adult ESL (English as a Second Language) conversation lessons. Each lesson (“a Spark”) is a structured plan built around a real cultural or intellectual source. The Service is delivered through a web browser at sparksesl.com.

Technical requirements (functionality and interoperability)

To use the Service you need a recent version of a modern web browser (Chrome, Firefox, Safari, or Edge — current and previous major versions) and a stable internet connection. The Service runs in your browser without a separate desktop or mobile app. Some interactive features may not work on browsers older than two years. Print and projection of lesson materials use standard browser printing. There is no DRM applied to the lesson materials inside the Service.

Compatibility

The Service is compatible with operating systems that run the supported browser versions above. Screen readers are supported for text-based content; visual elements include alternative text where available. See §A15 for our accessibility commitment.

Third-party services and links

The Service relies on third-party infrastructure (for example hosting, authentication, and, once paid plans launch, the Paddle checkout described in Part B) and may contain links to third-party websites, such as the ADR list at mimit.gov.it. We do not control and are not responsible for the content, products, or practices of third-party services or linked sites, and a link is not an endorsement. Your use of a third-party service is governed by that third party’s own terms and privacy notice, not these Terms. This does not affect our own responsibility for the Service itself or your statutory rights as a consumer.

You need an account to use most of the Service. You agree to:

• provide accurate, current information when you sign up and keep it up to date;
• maintain the security of your password and not share it;
• be responsible for everything done through your account, unless you have told us that your credentials were compromised;
• notify us immediately of any unauthorised access at hello@sparksesl.com.

Accounts are personal and non-transferable. A single account covers one teacher using the Service with their own students. If you need multiple seats for colleagues, contact us.

Transactional vs. marketing emails

Creating an account means we may send you transactional emails needed to operate the Service (sign-up confirmation, password reset, and important service notices). These are part of the contract and you cannot opt out of them while you have an account. Our newsletter and other marketing emails are a separate opt-in: you only receive them if you subscribe, confirm via double opt-in, and stay subscribed. You can unsubscribe from marketing emails at any time through the one-click link in every email, without affecting your account.

All lesson content, prompts, slide layouts, typography, software, and brand assets in the Service are owned by Sparks or our licensors and protected by Italian and international copyright and trademark law.

We grant you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable licence to use the Service for its intended purpose. While you have access you may:

• view and use lesson materials inside the Service;
• print or project lesson materials to teach your own students, including online over video;
• make a reasonable number of copies for your own classroom use.

You may not:

• redistribute lesson materials outside your own classes;
• remove or obscure copyright, credit, or watermark marks;
• offer paid tutoring programs whose core deliverable is unmodified Sparks lesson materials bundled as a standalone product.

You may use the Service to prepare and teach adult ESL lessons to your own students. You agree not to:

• resell, sublicense, publish, or redistribute Sparks lesson materials, in whole or in part, except to the extent required to teach your own classes;
• scrape, crawl, or systematically extract content from the Service, including through automated means or AI agents, except through any API we make officially available;
• reverse engineer, decompile, or attempt to derive the source code of the Service;
• use the Service to build a competing product, to train a generative model, or to populate a third-party content library;
• attempt to gain unauthorised access to the Service, probe or scan its security, or interfere with its operation;
• use the Service in any way that is unlawful, infringing, defamatory, harassing, or that violates the rights of others;
• impersonate another person or misrepresent your affiliation;
• use the Service in jurisdictions subject to EU or UN sanctions, or in breach of Italian or EU export controls.

We may suspend or terminate your account if you materially breach these rules (§A12).

Non-discrimination of EU consumers (Geo-blocking)

In accordance with Regulation (EU) 2018/302 we do not restrict EU consumers from accessing the Service on the basis of nationality, place of residence, or place of establishment within the EU. The sanctions and export-control restriction above applies only to jurisdictions outside the EU that are subject to mandatory restrictive measures under Italian or EU law.

Reporting illegal content

If you become aware of illegal content stored or transmitted through the Service, please notify us at hello@sparksesl.comwith the subject line “Illegal content notice”. Once we have actual knowledge of illegal content we will act expeditiously to remove or disable access to it, in accordance with Articles 14–17 of D.Lgs. 70/2003 and Articles 16 and 17 of the EU Digital Services Act (Regulation (EU) 2022/2065).

“Your Content” is anything you submit to the Service: student group labels, notes, customised lesson metadata, support messages, and anything else you add. You retain all ownership and intellectual property rights in Your Content.

You grant us a limited, worldwide, royalty-free, non-exclusive licence to host, store, reproduce, and display Your Content solely to operate, secure, and deliver the Service to you, and to make backups. The licence ends when you delete Your Content, subject to our backup rotation cycle (up to 35 days) and any legal retention obligations (§6 of the Privacy Policy).

You are responsible for Your Content and warrant that you have the right to submit it. Do not upload personal data of your students beyond the minimum necessary for organising your teaching (first names, group labels); do not upload sensitive-category data (GDPR Art. 9).

No training on Your Content

We do notuse Your Content to train, fine-tune, or evaluate any generative AI model, ours or a third party’s. Your Content stays inside the operational data plane of the Service. If we ever propose to change this, we will give you advance notice and require your opt-in consent.

Moderation

We may remove or disable access to Your Content if it breaches §A5 or is illegal, in accordance with Article 17 of the EU Digital Services Act. Where we do, we will give you a statement of reasons as described in §A12.

The Service is currently free. We may change, limit, or discontinue free beta features.

Paid subscriptions are not yet available. There is no checkout, so no charges, auto-renewals, or payment obligations apply to you today.

The subscription terms in Part B— pricing, Paddle as Merchant of Record, billing, auto-renewal, the right of withdrawal, and refunds — take effect only when we launch paid plans and the checkout that supports them, on notice. Until that launch, Part B is not binding and nothing in it can charge you.

Sparks lesson content is produced with a structured pipeline that uses a large language model (LLM) to draft each lesson from a verified real-world source, followed by a model-driven check pass and a human curation step that decides what ships. Slide layouts, the teaching method, software, brand, and the choice of source for each lesson are designed and selected by a human. The visual chrome of every Spark is not AI-generated.

Under Article 50 of the EU AI Act (Regulation (EU) 2024/1689), applicable from 2 August 2026, we make this disclosure so you can make an informed choice. We do not use AI to make automated decisions about your account, your access, or your support requests. Customer-support replies are written by a human.

We do not train any third-party AI model on Your Content (§A6), and §A5 prohibits using the Service to train a generative model.

Subject to mandatory consumer protections under Italian and EU law, the Service is provided “as is” and “as available”. To the maximum extent permitted by law, we disclaim all implied warranties including merchantability, fitness for a particular purpose, and non-infringement. We do not warrant that the Service will be uninterrupted or error-free. This does not affect your non-excludable statutory or consumer rights.

Conformity of the digital service

Under Articles 135-octies and following of the Italian Consumer Code (D.Lgs. 206/2005), transposing Directive (EU) 2019/770 on contracts for the supply of digital content and digital services, we are required to supply a digital service that conforms to the contract, including any description we publish, the purpose you reasonably expect it for, and ordinary quality standards. We must also provide updates necessary to keep the Service in conformity, including security updates, throughout the period of supply (Art. 135-duodecies).

If the Service is not in conformity

1. You can ask us to bring the Service into conformity (free of charge, within a reasonable time, and without significant inconvenience to you) by writing to hello@sparksesl.com.
2. If we cannot or refuse to bring it into conformity, if the non-conformity persists despite our attempt, or if the problem is serious enough to justify it immediately, you are entitled to a proportionate price reduction (where you have paid) or, where the non-conformity is not minor, to terminate the contract (Art. 135-quinquiesdecies and 135-septies decies).

The burden of proving conformity at the time of supply lies with us for any non-conformity that becomes apparent within one year of supply, in line with Art. 135-quaterdecies(3) Codice del Consumo.

Consumer rights: if you are a consumer, nothing in these Terms limits or excludes your statutory rights under the Italian Consumer Code (D.Lgs. 206/2005), including the conformity-of-digital-service rights under Articles 135-octies through 135-vicies ter. Those rights apply in addition to anything written here.

If you are a consumer within the meaning of the Italian Consumer Code, our liability for damages arising out of or in connection with the Service or these Terms is governed by Italian law, including the Italian Civil Code (Art. 1218, 1223, 1227, 1229) and the conformity-of-digital-service regime in Art. 135-octies and following of the Consumer Code. Nothing in these Terms limits or excludes our liability to a consumer beyond what Italian law permits.

If you are acting in the course of a business or profession and are not a consumer, our liability to you for any claim arising out of or in connection with the Service or these Terms is limited to the maximum extent permitted by applicable law. In a business context we are not liable for indirect, incidental, special, or consequential damages, loss of profit, loss of business opportunity, or loss of data, save where such exclusion is not permitted by law.

In every case, nothing in these Terms limits or excludes our liability for: (i) fraud or fraudulent misrepresentation; (ii) gross negligence or wilful misconduct (colpa grave o dolo, Art. 1229 c.c.); (iii) death or personal injury caused by our negligence; or (iv) any liability that cannot be limited or excluded under applicable mandatory law, including the Italian Consumer Code.

Your responsibility for your own breach

If you use the Service in the course of a business or profession and are not a consumer, you will reimburse us for third-party claims, and our reasonable directly related costs, that arise specifically from your own breach of these Terms, your misuse of the Service, Your Content, or your violation of law. We will notify you of any such claim, not settle it without your consent (not to be unreasonably withheld), and let you participate in the defence. This is limited to loss actually caused by your own fault.

If you are a consumer, this paragraph does not apply. We do not ask consumers to indemnify us; your liability to us is limited to what mandatory Italian and EU consumer law provides, and nothing here shifts our own risk onto you.

We will use reasonable efforts to keep the Service available. We do not guarantee specific uptime levels and are not liable for downtime due to maintenance or third-party infrastructure failure beyond our reasonable control. Italian Consumer Code Art. 135-duodecies requires us to provide updates, including security updates, necessary to keep the Service in conformity throughout the period of supply; we do.

When and why we may modify the Service

Beyond what is necessary to keep the Service in conformity, we may modify the Service only for the following specified valid reasons, in accordance with Art. 135-vicies of the Italian Consumer Code (transposing Digital Content Directive 2019/770 Art. 19):

• to add, improve, or update features and content;
• to address security, fraud, or abuse risks;
• to maintain compatibility with third-party platforms, browsers, devices, or operating systems we rely on;
• to comply with applicable law, a regulatory order, or a court decision;
• to retire a feature that has been replaced or is no longer technically supportable.

Any such modification will be made at no additional cost to you and we will inform you in advance by email or in-product notice where the change is more than minor.

Your right to terminate if the change harms you

Where a modification negatively impacts your access to or use of the Service in more than a minor way, you can terminate this contract free of charge within 30 days of receiving notice of the change or of the change being made, whichever is later. Where you have paid for a period, we will refund the unused portion in proportion (Art. 135-vicies(3) Codice del Consumo).

Events beyond our reasonable control

Neither party is liable for failure or delay in performing obligations under these Terms (other than payment) that is caused by events beyond reasonable control: natural disasters, acts of public authorities, internet or third-party infrastructure outages, war, civil disturbance, pandemic, or large-scale cyber-attack. We will use reasonable efforts to restore service as soon as practicable and to keep you informed. This clause does not limit your statutory rights under the Italian Consumer Code in respect of non-conformity of the Service.

You can stop using Sparks at any time and delete your account from your account settings or by writing to hello@sparksesl.com.

When we may suspend or terminate

We may suspend or terminate your account, or restrict the visibility or use of content you have submitted, only for one of the following reasons: material breach of these Terms, a suspected fraud, a serious security or abuse incident, or a legal or regulatory requirement. Except where immediate action is necessary to prevent harm, we will give you at least 14 days’ notice and a reasonable opportunity to cure.

Statement of reasons (DSA Article 17)

Where we impose a restriction on your account or your content, we will give you a clear, specific, and individualised statement of reasons, in accordance with Article 17 of the EU Digital Services Act (Regulation (EU) 2022/2065). The statement will identify: (a) the facts and circumstances that led to the decision; (b) the specific provision of these Terms or applicable law that was breached; (c) whether automated means were used to detect or decide on the restriction (today: no — every restriction is decided by a human); (d) the territorial scope; and (e) your right to challenge the decision through our internal complaint system, through an ADR body, or through the courts.

Internal complaint-handling system (DSA Article 20)

If you disagree with a decision to suspend, terminate, or otherwise restrict your account or content, you can submit a complaint free of charge by writing to hello@sparksesl.comwith the subject line “DSA complaint” within 6 months of the decision. A human reviewer will examine the complaint and respond with a reasoned decision in writing within a reasonable time. If we made a mistake we will reverse the decision and restore access without delay. The internal complaint route is in addition to your right to use an ADR body or the courts (§A14).

Effect of termination

On termination, your right to use the Service ends. We will retain and delete data as described in §6 of the Privacy Policy.

We may update these Terms for specified, legitimate legal, technical, or commercial reasons. We will notify registered users by email at least 30 days before a material change takes effect, and we give you a 30-day right to terminate free of charge if a change is to your detriment. Changes apply prospectively. If you do not accept a change, you can stop using the Service before it takes effect.

We will not make these Terms one-sided or illusory: any reason we rely on must be a real, stated reason of the kind listed above, and a change that materially reduces your rights triggers the termination right in the previous paragraph.

These Terms are governed by Italian law, excluding its conflict-of-laws rules.

If you are an EU or UK consumer, you keep the mandatory protections and the courts of the country where you live: you may bring proceedings against us in the courts of the Member State in which you are domiciled (Art. 18(1) Regulation (EU) 1215/2012 — Brussels I bis), and the choice of Italian law here does not deprive you of the protection of mandatory provisions of the law of your habitual residence (Art. 6 Regulation (EC) 593/2008 — Rome I). Italian Art. 66-bis Codice del Consumo confirms this. We do not impose arbitration, a class-action waiver, or an exclusive foreign venue on consumers.

If you are acting in the course of a business, the Tribunale di Monza, Italy, has exclusive jurisdiction.

Alternative dispute resolution (ADR)

If you have a complaint that we have not been able to resolve in writing, you have the right to refer the dispute to an alternative dispute resolution body recognised by the Italian authorities under Title II-bis of the Consumer Code (D.Lgs. 130/2015 transposing Directive 2013/11/EU). The list of recognised ADR bodies in Italy is maintained by the Ministero delle Imprese e del Made in Italy at mimit.gov.it. Sparks has not committed to using a specific ADR body and is not obliged by law to do so, but we will engage constructively with any recognised body you choose.

The EU Online Dispute Resolution Platform previously available at ec.europa.eu/consumers/odr was discontinued on 20 July 2025 pursuant to Regulation (EU) 2024/3228 and is no longer a route for new complaints.

We work towards WCAG 2.2 AA conformance under the European Accessibility Act (Directive (EU) 2019/882) and publish accessibility information. Screen readers are supported for text-based content, and visual elements include alternative text where available. The conformance claim is matched to our accessibility audit and not asserted beyond it.

If you hit an accessibility barrier, tell us at hello@sparksesl.com and we will work with you on an accessible alternative.

Severability. If any clause of these Terms is held unenforceable, the remaining clauses remain in full force. The unenforceable clause will be modified only to the minimum extent necessary to make it enforceable.

Force majeure. See §A11 — neither party is liable for failures caused by events beyond reasonable control.

Assignment. You may not assign these Terms without our prior written consent. We may assign these Terms in connection with a reorganisation, merger, or sale of our business, provided we give you at least 30 days’ notice by email before the assignment takes effect and the assignment does not reduce your rights under these Terms. If you do not accept the assignment, you can stop using the Service before it takes effect.

Entire agreement. These Terms, together with the Privacy Policy, form the entire agreement between you and Sparks regarding the Service.

No waiver. A failure to enforce any right under these Terms is not a waiver of that right.

Notices. We give you notice by email to the address on your account or by an in-product message; it is treated as received when sent, unless we know it failed. Service-status and legal-change notices may also be posted on the Service. You give us formal notice by email to hello@sparksesl.com or by post to the registered address in §A1. It is your responsibility to keep your account email current (§A3).

No third-party beneficiaries. These Terms are between you and us, and create no enforceable rights for any other person, except that Paddle benefits from the Part B terms that describe its role.

Headings. Section numbers and headings are for convenience only and do not affect interpretation.

Language. These Terms are currently provided in English only. An Italian translation will be added when available; where one exists, for Italian consumers the Italian version prevails in the event of any conflict between the two (D.Lgs. 206/2005 art. 35). For consumers in other EU Member States you may receive these Terms in English or Italian and benefit from the mandatory consumer-protection provisions of the law of your habitual residence (Art. 6 Regulation (EC) 593/2008). For business users not acting as consumers, the English version controls.

General contact, support, and complaints: hello@sparksesl.com.

Privacy contact: privacy@sparksesl.com.

Postal mail:Soldato Matthew James — Via Torino 2, 20831 Seregno (MB), Italy.

Single point of contact (DSA Articles 11–12)

For the purposes of Articles 11 and 12 of the Digital Services Act (Regulation (EU) 2022/2065), our single electronic point of contact for users and for authorities of EU Member States, the European Commission, and the European Board for Digital Services is hello@sparksesl.com. We accept communications in English and Italian. We will acknowledge messages from authorities without undue delay and respond as the matter requires.

Part B is not yet active.It is forward-looking. It becomes binding only once paid plans and the supporting infrastructure are actually built and launched, on notice — specifically once all of the following exist:

• a checkout that captures the auto-renewal consent in §B3 (ROSCA / state-ARL style consent) before payment details are entered;
• click-to-cancel online self-service that is at least as easy as signing up;
• the EU 14-day withdrawal flow with immediate-performance consent and the mandatory EU Withdrawal Button;
• the US auto-renewal reminder regime and the UK CCRs/DMCC cadence.

Until that launch, do not treat any clause in Part B as in effect. There are no charges, no auto-renewals, and no payment obligations under the current free Service (see §A7).

When paid plans launch, the Service will be offered on a recurring subscription basis (monthly or annual). The total price (including any VAT or sales tax applicable in your country of residence) will be shown at the checkout before you confirm.

Final pricing, free-tier limits, and any free-trial terms will be shown clearly before checkout. No price shown in pre-launch product materials creates a payment obligation.

When you subscribe (once paid plans launch) you enter into two separate agreements:

1. A service agreement with Sparks— Part A of these Terms. Sparks is responsible for providing the Service, the accuracy of product descriptions, content quality, uptime, and your experience inside the product.
2. A purchase agreement with Paddle.com Market Ltd(“Paddle”), our Merchant of Record. Paddle is the seller and legal counterparty for the payment transaction: it charges your payment method, issues the invoice, collects and remits VAT or sales tax, and handles refund and chargeback processing. Paddle’s own terms apply at checkout and are available at paddle.com/legal/checkout-buyer-terms.

Paddle.com Market Ltd is registered in England and Wales with registered address at Judd House, 18–29 Mora Street, London EC1V 8BT, United Kingdom. For VAT purposes Paddle is the supplier of record for your purchase. VAT or sales tax is added (or, for inclusive jurisdictions, included) at the rate applicable to your country of residence and is collected and remitted by Paddle. Invoices issued by Paddle are VAT-compliant in the EU under Council Directive 2006/112/EC and the e-commerce VAT regime in Council Directive (EU) 2017/2455.

Any invoice you receive will be issued by Paddle. Any charge on your card or bank statement will appear as a Paddle descriptor. This does not affect your service relationship with us: if something is wrong with the Service, write to us; if something is wrong with a charge or invoice, Paddle is the first port of call.

The Service will be provided on a recurring subscription basis (monthly or annual, as selected at checkout). The price displayed at checkout is the price you pay for the current billing period. Applicable VAT and sales tax are added or included according to your country of residence and are collected and remitted by Paddle as Merchant of Record.

Affirmative consent before payment (US ROSCA + state ARLs; EU/UK)

Subscriptions auto-renew at the end of each billing period at the then-current price until cancelled. Before you enter payment details, the checkout will disclose — clearly and at least as prominently as the pay button — the price, the billing cycle, that the subscription auto-renews, and how to cancel, and you will give affirmative, un-bundled consent (no pre-ticked box). You then receive a retainable confirmation. These steps satisfy the US ROSCA / state automatic renewal laws and the EU/UK subscription-transparency rules, and are part of why Part B cannot take effect until the checkout that captures this consent exists.

Renewal reminders

For annual subscriptions we send a reminder by email before the renewal date. For monthly subscriptions we send the renewal receipt on the day of the charge. Both messages include a one-click link to cancel before the next renewal.

Failed payments

If a renewal charge fails, Paddle will retry for a short period. If we cannot collect payment, we may suspend or terminate your subscription and access to the Service. We will notify you by email before suspension.

You will be able to cancel at any time through online self-service that is at least as easy as signing up (click-to-cancel) — the “Cancel my subscription” control reachable from the same place where you signed up, in line with EU Directive (EU) 2023/2673 on the cancellation of subscription contracts — or by writing to hello@sparksesl.com. Cancellation takes effect at the end of the current billing period and you keep access until then. We do not pro-rate refunds for the unused portion of a period, except where required by mandatory law or §B5 (right of withdrawal).

Switching and termination (EU Data Act)

Independently of the right of withdrawal, you may terminate the Service at any time with up to a two-month notice period (Reg. (EU) 2023/2854 art. 25, applicable to data-processing services from 12 September 2025). On request and within 30 days of termination we will provide an export of your account data, saved lessons, and group labels in a structured machine-readable format (JSON) so you can move to a different provider.

If you are a consumer in the EU or the United Kingdom, you will have the right to withdraw from your purchase within 14 days from the day the contract is concluded — for Sparks, the day Paddle confirms your subscription has been activated — without giving any reason, under Articles 52–59 of the Italian Consumer Code (D.Lgs. 206/2005) transposing Directive 2011/83/EU. UK: the Consumer Contracts Regulations (CCRs) cooling-off applies now; ahead of autumn 2026 we will build the DMCC reminder cadence and per-renewal cooling-off.

Immediate performance and when the right is lost

The Service is a digital service provided without a tangible medium. Under Art. 59(1)(o) of the Italian Consumer Code, the right of withdrawal is lost, or a pro-rata amount may be owed, only if:

• performance of the service has begun with your express prior consent; and
• you acknowledged at checkout that you lose the withdrawal right (or owe a pro-rata amount) once performance has started.

Both steps are captured on a non-pre-ticked control at checkout and confirmed on a durable medium. If you did not give both, or if you are within 14 days and performance has not begun, you can withdraw and receive a refund within 14 days of our receiving notice of your withdrawal, using the same means of payment used for the original transaction unless you expressly agree otherwise (Art. 56(1)–(3) Codice del Consumo). [Design note: in light of AG Opinion C-234/25, design for pro-rata refund exposure rather than a total waiver of the right.]

The EU Withdrawal Button (mandatory from 19 June 2026)

For EU consumers, a permanent “Withdraw from contract here” Withdrawal Button is mandatory from 19 June 2026 and must be built into the subscriber account before Part B binds EU consumers.

How to withdraw

Send a clear statement of your decision to withdraw to hello@sparksesl.com(or in writing to Soldato Matthew James — Via Torino 2, 20831 Seregno (MB), Italy), or use the EU Withdrawal Button. You may, but are not required to, use the model withdrawal form set out in Annex I-B of D.Lgs. 206/2005 reproduced below.

Model withdrawal form (Annex I-B, D.Lgs. 206/2005)

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

To: Soldato Matthew James — Via Torino 2, 20831 Seregno (MB), Italy — hello@sparksesl.com

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

Ordered on (*)/received on (*):

Name of consumer(s):

Address of consumer(s):

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

Date:

(*) Delete as appropriate.

Paddle, as Merchant of Record, processes the refund to your original payment method within the statutory 14-day period. This does not affect any other refund rights under applicable law.

For US customers, the renewal reminders, pre-charge notices, and easy online cancellation required by ROSCA and the state automatic renewal laws (California and others) will apply. We will maintain a per-state reminder-window matrix so each customer receives the notices their state mandates, and the cancellation path will meet the click-to-cancel standard in §B4.

Price changes

We may change subscription prices from time to time. We will notify you at least 30 days before a price change takes effect on your subscription. If you do not accept the new price, you can cancel before the change takes effect and continue to pay the old price until the end of the current period.

Refunds

Refunds follow your statutory withdrawal and conformity rights (see §B5 and §A9). Pre-paid fees are otherwise non-refundable except where mandatory law requires, or where §A11 (a modification that harms you) or termination for our breach applies. If we terminate for a material breach attributable to you, pre-paid fees are non-refundable except where mandatory law requires otherwise.

Confirmation of contract on a durable medium

Within a reasonable time after the contract is concluded, Paddle (as Merchant of Record) sends you the invoice and a confirmation email that includes the essential terms of your subscription. We deliver these Terms and the Privacy Policy on a durable medium by making them available at fixed URLs you can save or print from your browser at any time. You can also request a current copy by email at any time.

Part B does not take effect until the following are built and available to subscribers:

1. The checkout capturing the §B3 affirmative auto-renewal consent before payment details are entered.
2. Click-to-cancel online self-service at least as easy as signing up (§B4).
3. The EU Withdrawal Button and the immediate-performance consent control (§B5).
4. The US ROSCA / state-ARL reminder matrix (§B6) and the UK CCRs/DMCC cadence (§B5).
5. Final monthly and annual prices, free-tier limits, and any free-trial terms.