Warranty and Complaints Policy

WARRANTY AND COMPLAINTS POLICY

Last updated: 10 November 2026

This Warranty and Complaints Policy (the "Policy") applies to consumer orders placed through the SparkVision online shop at www.sparkvision.tech for delivery to Bulgaria, Romania or another EU Member State to which delivery is made in accordance with the Terms and Conditions.

The Policy explains the consumer's rights under the legal guarantee of conformity, the terms of the SparkVision commercial warranty and the procedure for submitting and handling complaints. It supplements the Terms and Conditions of the online shop and does not limit the consumer's mandatory rights under EU, Bulgarian or Romanian law.

1. Seller and contacts

The seller is determined by the country of delivery selected when ordering:

• For orders delivered to Romania, the seller is SPARK VISION IS ROMANIA SRL, CUI 54581719, Nr. Reg. Com. J2026028294009, address: Str. Verzisori 6, Bl. D, Ap. B118, 040301, Sector 4, Bucharest, Romania.
• For orders delivered to Bulgaria and the other EU Member States except Romania, the seller is "SPARK VISION IS" OOD, UIC 206677712, address: 1 Krum Popov St., 1164 Sofia, Bulgaria.

Throughout this Policy, "SparkVision" means the relevant seller for the order, as stated in the order confirmation.

Customer support for orders delivered to Bulgaria is available at customer.support@sparkvision.tech and by telephone at +359 876 094 402.

Customer support for orders delivered to Romania is available at support.romania@sparkvision.tech and by telephone at +40 740 161 922, +40 774 29 83 24.

2. Legal guarantee of conformity

SparkVision is liable for any lack of conformity of the product with the sales contract which exists at the time of delivery and becomes apparent within 2 years of delivery. For products with digital elements supplied continuously over a period of time, SparkVision is liable for any lack of conformity that becomes apparent within that period, but not less than 2 years.

In the event of a lack of conformity, the consumer is entitled by law to have the product brought into conformity free of charge by repair or replacement and, under the conditions laid down by law, to a price reduction or termination of the contract. Free of charge means that the consumer does not pay for labour, materials, spare parts or transport and postage costs related to bringing the product into conformity.

A lack of conformity that becomes apparent within 1 year of delivery is presumed to have existed at the time of delivery, unless proven otherwise or unless this presumption is incompatible with the nature of the product or of the lack of conformity. Where the applicable law provides for a longer period, that period applies.

The detailed rules on the legal guarantee are set out in Section XII of the Terms and Conditions.

3. Commercial warranty

In addition to the legal guarantee, SparkVision provides a commercial warranty for the products it sells under the SparkVision brand. Unless a longer period is stated in the product's warranty certificate, the commercial warranty is 24 months from delivery.

The commercial warranty does not affect the consumer's rights under the legal guarantee. Regardless of the commercial warranty and its exclusions, if the product does not conform to the contract the consumer is entitled by law to the free remedies under point 2. The consumer may choose whether to make a claim under the legal guarantee or under the commercial warranty.

The commercial warranty is valid in the countries to which SparkVision delivers in accordance with the Terms and Conditions. The guarantor is the relevant seller under point 1. The warranty certificate is provided to the consumer on a durable medium at the latest upon delivery.

In the event of a conflict between this Policy, a warranty certificate and mandatory consumer law, the rule more favourable to the consumer applies.

4. Product warranty certificates

SparkVision publishes warranty certificates for all products it sells. The consumer should use the certificate that matches the product name and model shown on the product, packaging, invoice or accompanying documents. Certificates may contain information on the model, warranty period, covered components, exclusions, service instructions and safety warnings.

5. What the commercial warranty covers

The commercial warranty covers manufacturing defects and malfunctions that arise during normal use in accordance with the user manual, safety instructions, technical specifications and product documentation. For example: hardware defects, defects in accessories, charging problems or other problems that prevent the product from functioning as intended and are not caused by excluded use or external damage.

6. What the commercial warranty does not cover

The commercial warranty does not cover:

• improper use, negligence or use contrary to the user manual or safety instructions;
• unauthorised repair, modification, disassembly or attempted repair;
• damage from water, liquids, humidity or environmental conditions outside the stated specifications;
• damage from impact, dropping, crushing, pressure, fire, overheating or other external damage;
• damage caused by unsuitable chargers, cables, power supplies, accessories or incompatible third-party products;
• normal and cosmetic wear, scratches or marks that do not affect normal operation;
• gradual reduction of battery capacity with normal use;
• software problems caused by unsupported configuration, unauthorised software, user changes, malware or incompatible third-party services;
• loss of data, personal files, settings or user-created content;
• products whose serial number, product identifier or warranty information has been removed, altered or cannot reasonably be verified.

These exclusions apply only to the commercial warranty. They do not limit the consumer's rights under the legal guarantee where a product does not conform to the contract.

7. How to submit a complaint

A complaint may be submitted orally or in writing, at the consumer's choice:

• by e-mail to customer.support@sparkvision.tech (for orders delivered to Bulgaria or other EU Member States) or to support.romania@sparkvision.tech (for orders delivered to Romania);
• by telephone at +359 876 094 402 (for orders delivered to Bulgaria) or at +40 740 161 922, +40 774 29 83 24 (for orders delivered to Romania);
• in writing or in person at the address of the relevant seller under point 1;
• by any other means indicated in the online shop.

To speed up handling, we recommend that the complaint include, where available:

• first name, surname and preferred contact details;
• order or invoice number and country of delivery;
• product name and model, serial number or product identifier;
• date of purchase and date of delivery;
• a description of the problem and when it first appeared;
• photos or video, error messages, app or device version, where helpful;
• the preferred remedy (repair, replacement, price reduction or termination of the contract).

The absence of a separate proof of purchase is not a ground for refusing to handle the complaint where the purchase can be established from SparkVision's records. SparkVision may request additional information only to the extent reasonably necessary to identify the product, verify the warranty status or carry out diagnostics.

SparkVision confirms receipt of the complaint by e-mail or on another durable medium. For orders in Bulgaria, the confirmation contains the complaint's reference number from the complaints register.

8. Handling times

SparkVision examines the complaint and informs the consumer of its decision and the next steps without undue delay.

Repair or replacement under the legal guarantee is carried out free of charge, within a reasonable time and without significant inconvenience to the consumer, and this time may not exceed:

• for orders where the seller is SPARK VISION IS ROMANIA SRL – 15 calendar days from the seller being notified of the lack of conformity; the period may also be set by written agreement between the seller and the consumer, taking into account the nature and complexity of the goods, the nature and severity of the lack of conformity and the effort required to complete the repair or replacement;
• for orders where the seller is "SPARK VISION IS" OOD – 1 month from the seller being notified of the lack of conformity, for products without digital elements. For products with digital elements, a reasonable period applies, taking into account the nature of the product and of the lack of conformity.

9. Initial diagnostics

Some problems can be solved remotely – through setup guidance, a software update, a reset, diagnostics or an accessory check. SparkVision may suggest such steps before arranging a physical inspection. They are at the consumer's discretion, must not create a safety risk and do not suspend or extend the time limits under point 8.

10. Safety-related problems

If the product shows signs of overheating, swelling, smoke, a burning smell, electrical failure, a damaged battery casing, severe impact damage, liquid ingress or any other safety-related problem, the consumer should stop using it immediately and contact SparkVision before charging, wearing, transporting or sending it. SparkVision will provide specific packaging and transport instructions.

11. Service, inspection and transport

If a physical inspection or repair is needed, SparkVision provides instructions for sending or handing over the product. Products should not be sent to an office, service centre or third-party address without confirmation from SparkVision.

For claims under the legal guarantee, the cost of transport to and from the service centre is borne by SparkVision. SparkVision arranges courier collection and return or reimburses the consumer's costs. The same applies to justified claims under the commercial warranty.

The consumer makes the product available without undue delay after submitting the complaint, in the manner indicated by SparkVision. Where the product has not been made available for reasons attributable to the consumer, any resulting delay in repair or replacement is not considered a failure on the part of SparkVision.

Repairs are carried out by SparkVision or by an authorised service centre designated by SparkVision. For orders in Romania, customer service and warranty processing are provided by SPARK VISION IS ROMANIA SRL, and the repair may be carried out by the SparkVision service centre in Bulgaria. This does not extend the time limits under point 8 and does not result in any cost to the consumer.

12. Remedies

Under the legal guarantee, the consumer chooses between repair and replacement, unless the chosen remedy is impossible or would impose costs on SparkVision that are disproportionate compared with the other. The consumer is entitled to a proportionate price reduction or to terminate the contract where:

• repair or replacement is impossible or disproportionate;
• SparkVision has not carried out the repair or replacement in time or in accordance with the law;
• the lack of conformity reappears despite the attempt to bring the product into conformity;
• the lack of conformity is so serious that it justifies an immediate price reduction or termination of the contract;
• SparkVision has declared, or it is clear from the circumstances, that it will not bring the product into conformity within a reasonable time or without significant inconvenience to the consumer.

The contract cannot be terminated if the lack of conformity is minor. The burden of proving that the lack of conformity is minor lies with SparkVision. In the event of termination or price reduction, SparkVision refunds the amount due without undue delay and no later than 14 days, using the same means of payment, unless the consumer has expressly requested otherwise, at no cost to the consumer.

Under the commercial warranty, SparkVision may provide diagnostics or a software update, repair, replacement of the product or of the affected component or accessory, or another remedy in accordance with the warranty certificate.

13. Data, settings and personal content

Before sending the product for service, the consumer should, where technically possible, remove personal files, saved settings, personal labels, account connections and other personal content. If help is needed, the consumer should contact SparkVision before sending the product.

Some service actions (reset, repair, replacement or software restoration) may erase data or settings on the product or in the connected app. SparkVision is not liable for loss of data, except where mandatory law provides otherwise. Sending the product for repair does not give SparkVision the right to unrestricted access to its content; personal data is processed in accordance with the Privacy Policy.

14. Accessories, bundles and spare parts

The consumer should follow SparkVision's instructions on which items to send. If the complaint concerns an accessory, charger, cable, smart ring, external battery or other component of a bundle, SparkVision may also need to inspect the main product.

In the event of replacement under the legal guarantee, the consumer receives a product that conforms to the contract and is of the same type and quality as the one purchased. Refurbished or functionally equivalent products and parts may be used only under the commercial warranty, for paid repairs or with the consumer's express consent.

15. Products out of warranty

If the product is not covered by the legal guarantee or the commercial warranty, or the problem is caused by excluded use or external damage, SparkVision may offer paid diagnostics, paid repair, paid replacement, return of the unrepaired product or recycling guidance. The price and terms are communicated to the consumer, and the work is carried out only with the consumer's express consent.

16. Complaints register

SparkVision keeps records of complaints, service requests, warranty decisions, repair status, returned and replacement products and related correspondence. For orders in Bulgaria, SparkVision keeps a complaints register in accordance with the Consumer Protection Act. Personal data relating to complaints is processed in accordance with the Privacy Policy.

17. Relationship with the right of withdrawal

This Policy governs complaints about non-conforming products and warranty service. The consumer's right to withdraw from an online purchase without giving any reason within 14 days is governed by Section XI of the Terms and Conditions and by the Returns and Withdrawal Policy. The consumer is not required to use the withdrawal process to report a defective, damaged, incomplete, non-conforming or incorrectly delivered product.

18. Authorities and out-of-court dispute resolution

If the consumer is not satisfied with the decision on the complaint, they may turn to:

• in Bulgaria – the Commission for Consumer Protection (www.kzp.bg), including its conciliation committees;
• in Romania – the Autoritatea Națională pentru Protecția Consumatorilor (https://anpc.ro) or a competent alternative dispute resolution body;
• the competent court in accordance with the Terms and Conditions and the applicable law.

19. Mandatory consumer rights

Nothing in this Policy limits the consumer's mandatory rights under EU, Bulgarian or Romanian law. If a provision of this Policy conflicts with mandatory consumer law, the mandatory rule applies.