1. Seller Identity and Contact
Seller: Hugo Barrio García (trading as Trevam Intelligence Systems), sole trader (autónomo), Spain. VAT/NIF: ES10884735P. Address: Camino Arroyo de Arnao, s/n, Chiclana de la Frontera, Cádiz 11330, Spain. Contact: hello@trevam.com.
2. Definitions
- Consumer: a natural person acting outside their trade, business, craft, or profession (Directive 2011/83/EU; TRLGDCU).
- Business Customer: a buyer acting within their trade or business.
- Buyer / Licensee: the individual purchaser or, where purchased on behalf of an organisation, that organisation.
- Product: the EU AI Act Compliance Starter Kit — Buyer Edition, supplied as downloadable digital content (HTML and PDF reference documents, with copyable templates and documentation, plus editable templates where included). No physical medium.
- Platform: Gumroad, used for payment processing and download delivery.
3. Scope and Acceptance
These Terms govern the purchase, delivery, and use of the Product. By completing checkout and ticking the applicable acceptance checkboxes, the Buyer enters into a contract with the Seller under these Terms.
Where the Buyer is a Consumer, mandatory consumer rights under Spanish law (TRLGDCU; Real Decreto Legislativo 1/2007) and applicable EU Directives (2011/83/EU; 2019/770) apply and are not excluded by these Terms.
4. Pre-Contract Information (Summary)
Before completing purchase, the Buyer may access the following mandatory information, as required by TRLGDCU Article 97:
- Key characteristics: downloadable digital documentation kit (HTML/PDF/copyable templates) relating to EU AI Act compliance for Limited and Minimal Risk systems. Does not constitute legal advice.
- Delivery: instant download link upon payment via Gumroad.
- Technical requirements: updated web browser for HTML; updated PDF reader for PDF export; ability to open downloaded files.
- Interoperability: standard HTML and PDF formats. Tables and content are copyable into Word, Google Docs, or equivalent.
- Contract duration: one-time supply, no subscription.
- Updates: minor updates delivered for 90 days (commercial commitment — see clause 7).
- Withdrawal: Consumers retain a 14-day statutory right of withdrawal. The digital-content waiver exception is not currently applied at this checkout because the Gumroad checkout does not currently present a separate, unticked-by-default waiver checkbox. See clause 8 and the Refund Policy.
5. Ordering Process
Purchases are completed through Gumroad checkout. The contract is formed when the Buyer completes payment and, where required, ticks the applicable acceptance checkboxes. The Seller recommends the Buyer retain the confirmation email and a copy of these Terms as a durable record.
5a. Payment Processing and Merchant of Record
Gumroad acts as merchant of record for payment processing, tax handling, and refund execution. Trevam (Hugo Barrio García, sole trader) is the content licensor and supplier of the digital product.
6. Price, VAT, and Invoicing
Price: €149 (one-time payment), unless otherwise stated at checkout.
VAT/Tax: As merchant of record, Gumroad is responsible for calculating, collecting, and remitting applicable taxes at checkout in accordance with its Terms of Service and applicable law. The applicable rate depends on the Buyer's location and status.
B2B tax treatment: Business Customers with a valid EU VAT number should provide it at Gumroad checkout. Tax treatment (including potential reverse charge) is determined by Gumroad as merchant of record.
Invoicing: receipts and invoices are provided through Gumroad's checkout flow. Buyers requiring a specific invoice format may contact hello@trevam.com.
7. Delivery and Updates
Delivery: the Product is made available for download immediately following confirmed payment via Gumroad. Delivery is deemed complete when the download link is made available to the Buyer.
Commercial update commitment: the Seller will provide minor updates (corrections, source clarifications, template refinements) for 90 days from the date of purchase. Minor updates are delivered by email to the address used at checkout. Legislative changes or major structural updates may be released as new product versions, which may be priced separately.
Statutory updates (Consumers): nothing in this clause limits the Seller's obligation to supply updates necessary to maintain conformity of digital content where required under TRLGDCU (Article 115 ter, as amended by Real Decreto-ley 7/2021, transposing Directive (EU) 2019/770), including security updates where applicable.
Download issues: if the Buyer cannot access the download link or the file is corrupted, the Buyer should contact hello@trevam.com with their order ID and the Seller will restore access or re-deliver the file.
8. Right of Withdrawal
Statutory rule. Consumers have a 14-day right of withdrawal for distance contracts (Directive 2011/83/EU; TRLGDCU Article 102). The period runs from contract conclusion. Within this period, the Consumer may withdraw without giving reasons by sending a clear statement to hello@trevam.com.
Digital content exception — not currently applied. TRLGDCU Article 103(m) and Directive 2011/83/EU Article 16(m) allow the withdrawal right to be excluded for digital content supplied immediately, where the Consumer expressly consents, acknowledges the loss of the right, and the Seller confirms this on a durable medium. The Gumroad checkout used by this site does not currently present a separate, unticked-by-default waiver checkbox, so the conditions of Article 103(m) are not met. The 14-day withdrawal right is preserved.
See the Refund Policy for the procedure.
9. Refunds
Within the 14-day withdrawal period, the Consumer may withdraw under Section 8. Refunds are processed by Gumroad as merchant of record. Outside this period, refunds are at the Seller's discretion for cases including download failure, duplicate purchase, and material defect. Statutory conformity rights under Section 10 are not affected. See the Refund Policy for full details.
10. Consumer Conformity Rights (Digital Content Directive)
Where the Buyer is a Consumer, the Product must conform to the contract in accordance with TRLGDCU as amended by Real Decreto-ley 7/2021 (transposing Directive (EU) 2019/770).
- Liability period: for one-time digital content supply, the Seller is responsible for lack of conformity that becomes apparent within two years of delivery.
- Burden of proof: lack of conformity appearing within one year of supply is presumed to have existed at the time of supply, unless proved otherwise.
- Remedies: the Consumer may request the Seller to bring the content into conformity; if not possible or not done within a reasonable time, the Consumer may request a proportionate price reduction or termination of the contract, and damages where applicable under TRLGDCU.
Nothing in these Terms excludes or limits mandatory Consumer conformity rights.
11. Licence and Intellectual Property
The Product is licensed, not sold. The Seller grants the Buyer a non-exclusive, non-transferable, revocable licence to use the Product materials for internal business purposes (or personal use if the Buyer is a Consumer), subject to Spanish intellectual property law (Real Decreto Legislativo 1/1996) and the terms below.
Permitted use:
- Copy, edit, and adapt templates for internal use.
- Use adapted outputs in the Buyer's own procurement responses, internal documentation, and internal compliance records.
- Share adapted outputs internally with employees or contractors acting under the Buyer's control, solely for the Buyer's internal business purposes.
Prohibited use:
- Redistribute, resell, sublicence, or share the original materials (or substantially similar derivatives) outside the Buyer's organisation.
- Publish materials (or derivatives) publicly, including online repositories, template libraries, marketplaces, or public cloud sharing links.
- Provide the kit as a standalone deliverable to third-party clients as a substitute product.
- Remove copyright notices or proprietary marks.
Consultants, agencies, law firms, compliance firms, and advisors: the base licence does not authorise use of the kit (or substantially similar derivatives) to produce deliverables for external clients, nor repeated multi-client reuse. Client deliverables, consultant use, agency use, law/compliance firm use, or repeated multi-client reuse require an extended licence. Contact hello@trevam.com.
All rights not expressly granted are reserved by the Seller.
12. Nature of the Product — Not Legal Advice
The Product provides general information, orientation, and documentation templates relating to the EU AI Act. It does not constitute legal, tax, regulatory, or professional advice, and does not create an attorney-client or other professional relationship. The Seller does not guarantee that use of the Product ensures regulatory compliance. Each Buyer must adapt, validate, and implement the materials according to their specific system and context, and obtain qualified professional advice where appropriate.
The Product covers documentation support for Limited and Minimal Risk AI systems as defined under the EU AI Act. It does not cover High-Risk system conformity assessment, which requires specialist legal and technical implementation beyond the scope of this kit. The Product does not include consulting services, implementation support, or coverage of systemic-risk GPAI model provider obligations.
13. Limitation of Liability
Nothing in these Terms excludes or limits any liability that cannot be excluded or limited under mandatory applicable law, nor limits any mandatory Consumer rights (TRLGDCU; Directive 2011/83/EU; Directive (EU) 2019/770).
Subject to the above, and to the extent permitted by law:
- B2B: except in cases of fraud or gross negligence, the Seller's total liability for any claim arising under or in connection with these Terms shall not exceed the amount paid by the Buyer for the Product.
- The Seller is not liable for loss of profit, loss of business opportunity, loss of data, or indirect or consequential losses in a B2B context, to the extent permitted by law.
14. Force Majeure
Neither party shall be liable for failure or delay caused by circumstances beyond their reasonable control, including widespread platform outages, network failures, or natural events.
15. Complaints and ADR
Complaints should be directed to hello@trevam.com, with the order ID and a description of the issue. The Seller will respond within a reasonable time.
Spain ADR framework: Ley 7/2017, of 2 November. The Seller does not currently participate in a voluntary ADR scheme. The EU ODR platform (Regulation (EU) No 524/2013) was repealed by Regulation (EU) 2024/3228 (effective 20 July 2025) and is no longer available for new complaints.
16. Governing Law and Jurisdiction
B2B: these Terms are governed by Spanish law. For B2B disputes, the parties submit to the courts of Cádiz, Spain, unless mandatory law provides otherwise.
B2C: for Consumers, this clause does not restrict the Consumer's right to bring proceedings before the courts of their habitual residence, or to rely on the consumer jurisdiction protections under Regulation (EU) 1215/2012 (Articles 17–19). Consumer statutory rights under the applicable mandatory law of their country of residence are not affected.
17. Language Versions
These Terms are available in English and Spanish. In case of discrepancy between language versions, the Spanish version shall prevail for Consumers residing in Spain. For Business Customers, the English version may apply where expressly agreed.
18. Amendments
The Seller may update these Terms to reflect legal or operational changes. The version in effect at the time of purchase governs that transaction. The Seller recommends retaining the confirmation email and these Terms as a durable record.
19. Severability
If any provision of these Terms is held invalid or unenforceable, the remaining provisions remain in full force.