# spun.ink — Right of withdrawal

*Consumer withdrawal notice and model withdrawal form (FAGG)*

> Version 2026-08-22 · effective 2026-08-22 · English is the contract language.
> Content hash: the SHA-256 of the served bytes, printed on the page itself at
> `spun.ink/legal/withdrawal` and reproducible from the raw markdown at `spun.ink/legal/withdrawal.md`
> Part of the spun.ink Terms of Service. Accepting the Terms accepts this document. This notice is
> also mandatory statutory information: an agreement that departs from the Fern- und
> Auswärtsgeschäfte-Gesetz (FAGG) to a consumer's disadvantage has no effect (FAGG § 2), so nothing
> here can be shortened or waived by contract.
> Supersedes: version 2026-08-20, readable at `spun.ink/legal/withdrawal/2026-08-20`. That version
> described two checkboxes at checkout and a proportional charge on withdrawal; neither is collected
> and neither is charged, so this version says so and refunds in full instead. Every version stays
> reachable at `spun.ink/legal/withdrawal/<version>`.

---

## In short

> **This summary is not the contract.** It is here because we owe you plain language. If it and the
> numbered sections below disagree, the numbered sections and the statutory model texts in sections
> 13 and 14 are what count.
>
> - If you are a **consumer** and you take a paid plan, you may withdraw from that contract within
>   **14 days**, without giving any reason. The 14 days start the day after the contract is
>   concluded.
> - **Any clear statement works** — an e-mail is enough. You may use the model form in section 14,
>   but you do not have to.
> - We **refund** what you paid within 14 days of receiving your withdrawal, to the same payment
>   method, with no fee.
> - You pay **nothing** for the days you had the plan. We never ask you for the early-start request
>   that would let us charge for them, so there is nothing to deduct: you get the full amount back.
> - The **free plan** costs nothing, so there is nothing to withdraw from — you can delete a free
>   account at any time.
> - Withdrawal is **not** the same as cancelling. Cancelling is always possible, at any time, and
>   ends the plan at the end of the period you already paid for.

---

## 1. Who has this right

This notice is for **consumers**. Under Austrian law you are a consumer whenever the transaction is
**not** part of running a business of yours (KSchG § 1 Abs 1 Z 2, which the FAGG adopts in its
§ 1 Abs 1). Preparing to start a business does not yet make you a business: transactions a natural
person makes before their business is up and running are still consumer transactions (KSchG
§ 1 Abs 3). We treat every customer as a consumer unless a business declaration is on file for the
account.

The right described here applies to a **paid** spun.ink subscription — Pro or Agency — that you
concluded at a distance, that is, over the internet without meeting us: a "Fernabsatzvertrag" (FAGG
§ 3 Z 2). It is also a contract under which you are obliged to pay, which is the FAGG's own gateway
for coverage (FAGG § 1 Abs 1 Z 1). Every paid subscription with spun.ink is concluded that way.

If you paid for a plan and you are a consumer, sections 4 to 12 are about you.

## 2. The free plan

The free plan costs nothing. You pay no money for it, and we process the e-mail address and name on
the account only in order to provide the service and to meet our own legal obligations — not as a
price for it.

On our reading of FAGG § 1 Abs 1, a free account is therefore not a contract this notice applies to:
there is no payment to withdraw from and no amount to refund. You can stop using a free account at
any time and have it deleted through your Agent's `delete_account` tool; see the Terms of Service
(`/legal/terms`) for what deletion does.

*Honest note: this is our reading of the FAGG scope rule, not a settled point. It could change if we
ever started using account data for something other than providing the service — for example
marketing mail. If that happens, this section changes with it.*

## 3. Business customers *(business customers only)*

There is **no statutory right of withdrawal in a business-to-business contract**. If a business
declaration is on file for your account, the 14-day right in this notice does not apply to you. Your
cancellation rights are the ordinary contractual ones in the Terms of Service (`/legal/terms`):
monthly term, no minimum term, cancel at any time in the billing portal with effect from the end of
the period you have paid for.

Whether you are a consumer depends on the facts, not on the label on the account. An agreement that
departs from the consumer-protection rules to your disadvantage has no effect (KSchG § 2 Abs 2), so
a business declaration you did not mean to make cannot take a consumer protection away from you. If
you are a private individual who mistakenly entered business details, tell us at
`support@spun.ink` and we will correct
the record.

## 4. The 14 days

You may withdraw from the contract within **14 days without giving any reason** (FAGG § 11 Abs 1).

A spun.ink subscription is a **service**, so the period starts **on the day the contract is
concluded** (FAGG § 11 Abs 2 Z 1). The day of conclusion itself is not counted; the first of the 14
days is the day after.

The contract is concluded when your payment at Stripe Checkout succeeds and your paid plan starts.
This is the moment of conclusion for the **paid-plan** contract this notice is about — its own
distance contract (section 8), separate from the account-level Terms of Service contract, which is
concluded earlier, when you click the confirmation link in your sign-up e-mail. The exact date and
time are in the confirmation e-mail we send you, which is also where this notice and the model form
are reproduced in full — that mail is your durable copy (FAGG § 7 Abs 3). If our records and that
e-mail ever disagree about the date, we use the later one, because it gives you more time.

**The deadline is met by sending, not by arriving.** It is enough that you send your withdrawal
before the 14 days are over (FAGG § 13 Abs 1).

## 5. How to withdraw

Send us a **clear statement** that you are withdrawing from the contract. There is no prescribed
form (FAGG § 13 Abs 1). An e-mail is enough. A letter by post is enough. You do not have to give a
reason, and you do not have to use any particular words.

- **E-mail:** `support@spun.ink`
- **Post:** City of Code GmbH, Adnet 436, 5421 Adnet, Austria
- **Telephone:** +43 664 8111838

It helps us if you write from the e-mail address on the account, or name the account e-mail address
in the message, so we can find the right subscription.

You **may** use the model withdrawal form in section 14. It is optional. Using it changes nothing
about your rights.

**We do not offer an online withdrawal form today.** There is no button in the product and no web
form on this page. If we ever add one, we will confirm receipt of your withdrawal to you
immediately on a durable medium — normally by e-mail — as FAGG § 13 Abs 2 requires, and this notice
will be updated in the same release. See also section 16.

## 6. What we refund, and when

If you withdraw, we pay back everything we received from you — **without undue delay and at the
latest within 14 days** of the day your withdrawal reaches us (FAGG § 14 Abs 1).

- We refund to the **same payment method** you used, unless we have expressly agreed something else
  with you.
- **You are never charged a fee for the refund.**
- The refund is executed through Stripe, the payment service provider that took the original
  payment on our behalf. The contract and the invoice are with City of Code GmbH.
- We keep **nothing** — section 7.

*Honest note: refunds are done **by hand** by a person at City of Code. There is no automated
withdrawal or refund function in the product, and no tool your Agent can call to trigger one. That is
why section 5 asks you to write to us. The 14-day deadline is ours to keep either way.*

## 7. What you pay if you withdraw

**Nothing.** You get back everything you paid, with no deduction for the days the plan was running.

Austrian law lets us charge a proportional amount for a service already provided only if you first
**expressly requested** that we start inside the withdrawal period — FAGG § 16 Abs 1 makes the duty
conditional on a request under § 10. **We never ask you for that request** (section 8), so the
condition is never met and no proportional amount arises.

We start your plan immediately anyway, because that is what you are buying. The first 14 days being
at our risk is our decision, not something you owe us for. **No other charge may be imposed on you
because you withdrew** (FAGG § 16 Abs 4).

| | Pro | Agency |
|---|---|---|
| Net price per month | €19.00 | €199.00 |
| Gross price per month for a consumer in Austria (20 % VAT) | €22.80 | €238.80 |
| What comes back if you withdraw inside the 14 days | all of it | all of it |

The exact VAT depends on your country; Stripe calculates and shows it before you pay, and the gross
figure on your invoice is the amount we refund. If you are an EU business with a valid VAT
identification number, the reverse-charge procedure applies and the invoice carries no Austrian VAT —
but see section 3: businesses have no withdrawal right.

## 8. What you are asked to tick before you pay, and what you are not

FAGG § 10 would let us charge for an early start, but only against **two separate, actively ticked
declarations**: an express request to begin before the 14 days are over, and an acknowledgement that
the right ends once the service has been provided in full.

**We ask you for neither.** Checkout is Stripe's hosted page, and we have decided to keep it that
way rather than put a consent page of our own in front of it. Stripe's page carries one general
checkbox and no field we could use for two separate declarations, so the § 10 declarations are simply
not collected. What that costs is ours, not yours: section 7.

The one box you do tick at Stripe Checkout is your agreement to the **Terms of Service**, which
include this notice. It is not a § 10 declaration and we will not treat it as one.

We treat every paid checkout as its own distance contract, and a fresh 14-day period runs from each.

*Honest note: whether moving from one paid plan to another in the billing portal starts a new
withdrawal period is not settled in Austrian law or in chamber guidance. We assume it does, because
that is the reading that favours you.*

## 9. If we did not inform you properly

The law attaches consequences to our own failures, and we state them here rather than leave you to
find them:

- **If we never gave you this withdrawal information at all**, your withdrawal period is extended by
  **twelve months** on top of the 14 days (FAGG § 12 Abs 1). If we supply the information late,
  within those twelve months, the period ends 14 days after you receive it (FAGG § 12 Abs 2).
- **If we failed to inform you about the withdrawal right and about the proportional payment duty**,
  you owe **nothing** for the service already provided (FAGG § 16 Abs 2). This is moot here: you owe
  nothing in any case, because we never take the § 10 request (sections 7 and 8).

*Honest note: that the duty never arises at all without a valid § 10 request is our reading, not a
rule the statute spells out in so many words. FAGG § 16 Abs 1 makes the pro-rata duty conditional on
you having "ein Verlangen gemäß § 10 erklärt" — declared the request under § 10 — before we started.
We read the conditionality as we have written it, and we would not argue the other way against you.*

## 10. When the right ends — and the exception we do not claim

The 14 days simply run out. That is the normal end of the right.

There is one statutory exception for services: the right lapses where the trader has performed the
service **in full**, and then only if the consumer expressly consented to the early start and
confirmed beforehand that full performance ends the right (FAGG § 18 Abs 1 Z 1). Those are the very
declarations we do not collect (section 8), so the exception could not be reached even if we wanted
it.

**We do not claim that exception, and we will not argue it against you.** A spun.ink subscription is
a continuously provided service that renews monthly; there is no point inside your first 14 days at
which it has been "provided in full". We also do not claim the exception for digital content
delivered without a physical medium (FAGG § 18 Abs 1 Z 11) — that rule is written for downloads, and
a hosted subscription service is not a download.

If you withdraw within the 14 days, you withdraw, and you get everything back (section 7).

## 11. Your site and your content after a withdrawal

A withdrawal ends the **paid** contract. It is not a deletion of your account.

- Your account **returns to the free plan**. Downgrading never deletes anything: your sites,
  content, templates, collections, revisions and assets stay where they are, and the free-plan
  ceilings and the "Made with spun.ink" attribution banner apply again from then on. Like the
  refund, this reversion is carried out **by hand** by a person at City of Code when your withdrawal
  arrives; there is no automated withdrawal path in the product.
- After a withdrawal you may no longer use the paid features you withdrew from (FAGG § 16 Abs 5) —
  in practice, the plan simply reverts.
- **Getting your content out.** On request we give you a copy of the content you created, free of
  charge and in a commonly used, machine-readable format (FAGG § 14 Abs 7). Today there is **no
  one-click export tool**: the honest position is that the export path is the read tools of the MCP
  interface, which your own Agent can call, plus a copy we assemble by hand if you ask us at
  `support@spun.ink`. The Terms of Service (`/legal/terms`) describe the switching and export process
  in full.
- If you want the account and its data **erased** as well, that is a separate act: your Agent's
  `delete_account` tool, which requires you to confirm from your own mailbox. Billing records stay
  at Stripe for seven years because Austrian tax law requires it (BAO § 132).

## 12. Withdrawal and cancellation are different things

| | **Withdrawal** (this notice) | **Cancellation** |
|---|---|---|
| Who | Consumers only | Everyone |
| When | Within 14 days of concluding the paid contract | At any time |
| Reason needed | No | No |
| Effect | The paid contract is unwound; you pay nothing for the days served | The plan ends at the end of the period you have already paid for |
| Money back | Yes — all of it | No; the running period is not refunded |
| How | Any clear statement (section 5) | The Stripe billing portal, reachable through your Agent's `create_billing_portal_link` tool |

There is no minimum term and no early-termination penalty either way.

## 13. The statutory withdrawal notice (Muster-Widerrufsbelehrung, FAGG Anhang I Teil A)

The Austrian statute supplies a model text. Because it is the model, using it means the information
duty counts as met (FAGG § 4 Abs 3). It is reproduced here in German, filled in for this contract,
followed by an English translation.

**The German text in section 13.1 is the statutory model and the one that governs. The English text
in section 13.2 is a translation of it, provided for convenience. If the two ever read differently,
the German text applies.** The same is true of the model form in sections 14.1 and 14.2.

### 13.1 German (statutory model)

> **Widerrufsrecht**
>
> Sie haben das Recht, binnen vierzehn Tagen ohne Angabe von Gründen diesen Vertrag zu widerrufen.
>
> Die Widerrufsfrist beträgt vierzehn Tage ab dem Tag des Vertragsabschlusses.
>
> Um Ihr Widerrufsrecht auszuüben, müssen Sie uns (City of Code GmbH, Adnet 436, 5421 Adnet,
> Österreich, Telefon +43 664 8111838, E-Mail
> support@spun.ink) mittels einer eindeutigen Erklärung (z. B. mit der Post versandter Brief oder
> E-Mail) über Ihren Entschluss, diesen Vertrag zu widerrufen, informieren. Sie können dafür das
> beigefügte Muster-Widerrufsformular verwenden, das jedoch nicht vorgeschrieben ist.
>
> Zur Wahrung der Widerrufsfrist reicht es aus, dass Sie die Mitteilung über die Ausübung des
> Widerrufsrechts vor Ablauf der Widerrufsfrist absenden.
>
> **Folgen des Widerrufs**
>
> Wenn Sie diesen Vertrag widerrufen, haben wir Ihnen alle Zahlungen, die wir von Ihnen erhalten
> haben, einschließlich der Lieferkosten (mit Ausnahme der zusätzlichen Kosten, die sich daraus
> ergeben, dass Sie eine andere Art der Lieferung als die von uns angebotene, günstigste
> Standardlieferung gewählt haben), unverzüglich und spätestens binnen vierzehn Tagen ab dem Tag
> zurückzuzahlen, an dem die Mitteilung über Ihren Widerruf dieses Vertrags bei uns eingegangen ist.
> Für diese Rückzahlung verwenden wir dasselbe Zahlungsmittel, das Sie bei der ursprünglichen
> Transaktion eingesetzt haben, es sei denn, mit Ihnen wurde ausdrücklich etwas anderes vereinbart;
> in keinem Fall werden Ihnen wegen dieser Rückzahlung Entgelte berechnet.

*Three notes on the model text.* The model was written for goods as well as services, so it mentions
delivery costs; **a spun.ink subscription has no delivery costs, and none will ever be deducted from
your refund.** The model says "Widerruf" while the FAGG itself says "Rücktritt" — the two words mean
the same thing here. And the model's closing paragraph about paying a proportional amount is the one
the statute's own drafting instruction tells the trader to insert only where the consumer requested
an early start; we do not take that request (section 8), so the paragraph is left out rather than
promising a charge we have no basis to make.

### 13.2 English (translation of the model)

> **Right of withdrawal**
>
> You have the right to withdraw from this contract within 14 days without giving any reason.
>
> The withdrawal period will expire after 14 days from the day of the conclusion of the contract.
>
> To exercise the right of withdrawal, you must inform us (City of Code GmbH, Adnet 436, 5421 Adnet, Austria, telephone +43 664 8111838, e-mail
> support@spun.ink) of your decision to withdraw from this contract by an unequivocal statement
> (for example a letter sent by post or an e-mail). You may use the attached model withdrawal form,
> but it is not obligatory.
>
> To meet the withdrawal deadline, it is sufficient for you to send your communication concerning
> your exercise of the right of withdrawal before the withdrawal period has expired.
>
> **Effects of withdrawal**
>
> If you withdraw from this contract, we shall reimburse to you all payments received from you,
> including the costs of delivery (with the exception of the supplementary costs resulting from your
> choice of a type of delivery other than the least expensive type of standard delivery offered by
> us), without undue delay and in any event not later than 14 days from the day on which we are
> informed about your decision to withdraw from this contract. We will carry out such reimbursement
> using the same means of payment as you used for the initial transaction, unless you have expressly
> agreed otherwise; in any event, you will not incur any fees as a result of such reimbursement.

## 14. The model withdrawal form (Muster-Widerrufsformular, FAGG Anhang I Teil B)

The statute requires that this form be made available to you unaltered. **You do not have to use
it** — any clear statement works (section 5). Fill it in only if you want to withdraw.

### 14.1 German (statutory model)

> **Muster-Widerrufsformular**
>
> (Wenn Sie den Vertrag widerrufen wollen, dann füllen Sie bitte dieses Formular aus und senden Sie
> es zurück)
>
> — An City of Code GmbH, Adnet 436, 5421 Adnet, Österreich,
> E-Mail: support@spun.ink:
>
> — Hiermit widerrufe(n) ich/wir (\*) den von mir/uns (\*) abgeschlossenen Vertrag über den Kauf der
> folgenden Waren (\*)/die Erbringung der folgenden Dienstleistung (\*)
>
> — Bestellt am (\*)/erhalten am (\*)
>
> — Name des/der Verbraucher(s)
>
> — Anschrift des/der Verbraucher(s)
>
> — Unterschrift des/der Verbraucher(s) (nur bei Mitteilung auf Papier)
>
> — Datum
>
> (\*) Unzutreffendes streichen.

### 14.2 English (translation of the model)

> **Model withdrawal form**
>
> (Complete and return this form only if you wish to withdraw from the contract)
>
> — To City of Code GmbH, Adnet 436, 5421 Adnet, Austria, e-mail:
> support@spun.ink:
>
> — 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.

## 15. How to reach us

```
City of Code GmbH
Adnet 436, 5421 Adnet, Austria
E-mail: support@spun.ink   ·   +43 664 8111838
Withdrawal declarations: support@spun.ink
Commercial register: FN 362676y · Firmenbuchgericht: Landesgericht Salzburg
VAT identification number: ATU66573656
Managing director (Geschäftsführer): DI Norbert Egger, BSc
```

spun.ink is a product and service of City of Code GmbH. The full identification details, the
contact points for authorities and for recipients of the service, and the supervisory authority are
in the Legal notice (`/legal/imprint`).

Withdrawal declarations go to `support@spun.ink`; reports about content go to `abuse@spun.ink`.
Those are the two addresses this company publishes, and a person reads both.

If a dispute about a withdrawal cannot be settled with us directly, the dispute-resolution section
of the Terms of Service (`/legal/terms`) names the alternative dispute resolution body you can
approach and states whether we take part. There is no European online dispute resolution platform
any more — it was discontinued on 20 July 2025 — so we do not point you at one.

## 16. Watch item — the withdrawal button (§ 13a FAGG, contracts concluded after 30 September 2026)

The Verbraucherrechts-Änderungsgesetz 2026 (BGBl. I Nr. 59/2026) has been enacted. It inserts a new
**§ 13a FAGG** and replaces **Anhang I** — the model notice and the model form reproduced in
sections 13 and 14. Under FAGG § 20 Abs 5 those provisions enter into force on **1 October 2026** and
apply to contracts concluded **after 30 September 2026**. A further set of changes (FAGG § 3 Z 16 to
20, § 4 Abs 1 Z 7, Z 12, Z 12a to 12d and Z 20 and 21, § 8 Abs 1, Anhänge II and III) enters into
force on **27 September 2026** for contracts concluded after 26 September 2026 (FAGG § 20 Abs 6).

Practical effect, stated as what we know and what we do not:

- **Known:** § 20 Abs 5 replaces **Anhang I** — the annex the model texts in sections 13 and 14 come
  from — with the version enacted by the amendment, for contracts concluded after 30 September 2026.
  What that replacement changes is *not* knowable from the text we hold: it may reword Teil A and
  Teil B, or it may only add to them. Either way, sections 13 and 14 must be checked against the
  enacted Anhang I before that date.
- **Not yet verified, and this is the larger question:** whether § 13a reaches a contract like yours
  at all. The amending act's own implementation note says it transposes Directive (EU) 2023/2673 on
  **distance contracts for financial services** and Directive (EU) 2024/825. The provisions that
  § 20 Abs 5 brings into force alongside § 13a — a new § 1a, a new § 3 Z 3a, a new section heading
  after § 18 and new §§ 18a to 18d — read like a self-contained financial-services regime, and a
  spun.ink subscription is not a financial service. Chamber guidance nonetheless describes § 13a as
  a general mandatory online withdrawal function — a "Widerrufsbutton" with an immediate receipt on
  a durable medium, along the lines of the German rules already in force. The consolidated statute
  we hold carries only the entry-into-force note, not the § 13a text, so we neither restate it nor
  assume it applies to us.
- **What we will do:** re-verify this notice against the amendment and reissue it as a new version
  before 30 September 2026.

Section 5 states honestly that no online withdrawal form exists today. If we build one to meet
§ 13a, we will also add the immediate durable-medium acknowledgement that FAGG § 13 Abs 2 already
requires of anyone who offers such a form.

## 17. The other spun.ink legal documents

| Document | Where |
|---|---|
| Terms of Service | `https://spun.ink/legal/terms` |
| Privacy Notice | `https://spun.ink/legal/privacy` |
| Legal notice (Impressum, Offenlegung, contact points) | `https://spun.ink/legal/imprint` |
| Data Processing Agreement | `https://spun.ink/legal/dpa` |
| Acceptable Use Policy | `https://spun.ink/legal/acceptable-use` |
| Right of withdrawal (this document) | `https://spun.ink/legal/withdrawal` |

Each of them is served both as an HTML page and as raw markdown at the same address with `.md`
appended, with no login and no JavaScript required.

If you are looking for a separate "Digital Services Act" page or a separate sub-processor list:
there is none. The contact points, the supervisory authority and the service-category statement are
in the Legal notice; the content rules, the moderation procedure and the notice-and-action channel
are in the Terms of Service; the sub-processor list and the technical and organisational measures
are Annexes 1 and 2 of the Data Processing Agreement.

Where these documents disagree: the Data Processing Agreement prevails on data-protection matters,
**this notice prevails on withdrawal mechanics**, and otherwise the Terms of Service prevail.

## 18. Version, changes and language

- **Version 2026-08-22**, effective 2026-08-22. Supersedes version 2026-08-20, which described two
  checkboxes at checkout and a proportional charge on withdrawal. Neither exists: the declarations
  are not collected and nothing is deducted from a refund. The change is in your favour, so it takes
  effect with this version rather than after a notice period.
- The content hash of the exact bytes served is not written inside this file — a hash written into
  the file it describes cannot be computed. It is printed on the served page and is the SHA-256 of
  the raw markdown at `spun.ink/legal/withdrawal.md`, which you can verify yourself.
- A new version is a new file version, never an edit in place. The previous text stays in the
  repository and is listed in the changelog with its effective date.
- **English is the contract language.** The German text in sections 13.1 and 14.1 is the Austrian
  statutory model; the English text in sections 13.2 and 14.2 is a translation of it.
- Changes to this notice are announced the same way as changes to the Terms of Service: by e-mail to
  the address on your account, at least 30 days before they take effect. Nothing is switched off,
  suspended or restricted because you have not answered a change notice.