Terms of Service

Suelto is a paid subscription for learning Peninsular Spanish. These terms are governed by Spanish and EU law. Consumer rights under your country of residence remain unaffected.

1. Provider and contact (Art. 10 LSSI)

The service at suelto.es (including suelto.es/signin), suelto.es/app and the API at suelto.es/api is operated by:

Elevate Studio
Legal Iuris La Zenia, C. Salzillo, S/n, 03189 Orihuela, Alicante, Spain
Email: hola@suelto.es — Contact: suelto.es/contact · Umut Gokbayrak

References to “Suelto”, “we”, “us” mean that entity. “You” means the registered user. The designated contact for complaints and out-of-court dispute requests is hola@suelto.es.

2. What Suelto is

Suelto is a subscription software-as-a-service for adults learning Peninsular (European) Spanish. It combines adaptive lessons, conversation practice with AI transcription and feedback, spaced repetition, and a daily loop (Learn · Lesson · Speak · Review). The service is provided as a digital content / digital service within the meaning of Directive (EU) 2019/770 and Arts. 114 et seq. TRLGDCU.

We target Spain’s variety — vosotros, local register and real-world scenarios — but we do not promise any specific exam outcome (DELE/EOI) or fluency level by a fixed date.

3. Eligibility and accounts

• You must be 18 or older and capable of entering a binding contract.
• You must provide a valid email address and keep access to that email account secure. Authentication is passwordless via magic link: we email you a single-use link that expires in 15 minutes. You must keep sign-in links confidential, not forward them, and not share a logged-in device or session. You are responsible for all activity under your account. No password is set or stored at any time.
• One natural person per account. Accounts are personal, non-transferable and may not be shared, resold or pooled.
• Sign-up and sign-in are the same flow: entering your email at suelto.es/signin (or in the app at suelto.es/app) triggers a magic link; clicking the link verifies your email and either creates your account (first use) or signs you in (returning user). The link is single-use, SHA-256-hashed at rest and consumed on first verification. We may suspend or close accounts that breach these terms, impair security, or create unreasonable load, after notice where feasible. Rate limits apply: 5 requests/hour per IP and 3/hour per email.

4. Subscriptions, price and invoicing

• Plans: 30-day free practice, Pro and Intensive as described at suelto.es/pricing. Features and daily caps for each plan are shown at checkout and in-app at Plan & billing. The free practice period lasts 30 days from registration; after expiry, AI-powered features require a paid subscription. Account data is preserved indefinitely.
• Price and currency: Prices are shown at checkout in USD as displayed at suelto.es/pricing (Pro $39/mo or $348/yr, Intensive $59/mo or $540/yr), billed monthly or annually. Where VAT/GST applies in your jurisdiction it is collected as shown at checkout. Invoices are issued via Stripe.
• Billing provider: payments are processed by Stripe Payments Europe Ltd. (Ireland) and/or Stripe, Inc. We never see your card number — only a Stripe customer ID and invoice metadata. Stripe is the payment processor; Suelto remains the merchant of record.
• Cycle: paid plans bill monthly in advance from the subscription date. Charges recur automatically until cancelled.
• Invoices: issued electronically via Stripe and downloadable at Plan & billing → Invoices and via the Stripe customer portal. Electronic invoicing is accepted per Art. 29 LSSI.
• Price changes: we may change prices with at least 30 days’ notice by email and in-app. New prices apply at the next renewal; you may cancel before then if you do not accept them.

5. Renewal, cancellation and refunds

• Renewal: subscriptions renew automatically each billing period.
• Cancellation: you can cancel at any time from Plan & billing → Manage billing (Stripe portal) or by emailing hola@suelto.es. Cancellation takes effect at the end of the current period; you retain full access until then. No partial-period refunds except where required by law or §6.
• Free plan: stays free indefinitely subject to fair-use caps and these terms.
• Refunds for defective service: if the service does not conform with the contract (Arts. 119–126 TRLGDCU, transposing Directive (EU) 2019/770) you may request bringing it into conformity, a proportionate price reduction or — in serious cases — termination and a pro-rata refund. Write to hola@suelto.es within 14 days of the charge with details; we handle cases individually and within the statutory time limits.

6. Right of withdrawal (Art. 102 et seq. TRLGDCU)

If you are an EU consumer, you have a statutory 14-calendar-day right of withdrawal from the date of purchase without giving reasons.

How to exercise: send an unequivocal statement (e.g., “I withdraw from my Suelto subscription purchased on [date]”) to hola@suelto.es or via the Stripe portal before the 14 days expire. We will confirm receipt and, where the conditions below do not apply, refund to the original payment method within 14 days.

Exception for immediate digital services (Art. 103(a) and (m) TRLGDCU): because Suelto provides immediate access to digital content and digital services, once execution has begun with your prior express consent and your acknowledgment that you lose the right of withdrawal once the service has started, the right of withdrawal is lost for the supplied portion. At checkout we present a checkbox to that effect and do not start the paid service until you accept. If you do not give that consent, execution does not begin until the 14 days expire.

Proportionate payment: if you requested immediate execution and then withdraw within 14 days before the current period’s service is fully supplied, we may charge a proportionate amount for what was already provided (Art. 108.3 TRLGDCU); the remainder is refunded.

Business customers and non-EU consumers do not have this statutory withdrawal right, but §5 refunds for lack of conformity still apply.

7. Acceptable use

You agree not to:

• Use the service for unlawful, defamatory, harassing or infringing purposes.
• Scrape, crawl, bulk-extract or systematically reproduce AI-generated lessons, audio or corrections for resale, dataset creation or to train competing models.
• Reverse-engineer, overload, or attempt to bypass rate limits, paywalls or security (e.g., sharing magic-link tokens or sessions, credential stuffing).
• Upload unlawful content or content you do not have rights to.

We may rate-limit, suspend or terminate access for serious or repeated misuse, with or without prior notice where urgent security requires it.

8. AI-generated content — disclaimer

Lessons, conversations, corrections, readings, listening scripts, Writing Lab story scenes and scenario replies are generated by AI models (Anthropic Claude via Cloudflare AI Gateway; Writing Lab scenes via Meta’s Muse Spark; transcription/speech via Workers AI and ElevenLabs). They aim to model Peninsular Spanish accurately but may contain errors, biases or hallucinations. They are language-learning aids, not professional advice. Do not rely on them for legal, medical, financial or official purposes — consult a qualified professional (your gestor, lawyer, doctor, etc.).

We monitor quality and may change prompts, models or providers at any time. Feedback you submit about corrections helps improve personalisation but does not guarantee correction to your preference.

9. Your content and licence

Your notes, captures, voice recordings, answers and practice history (“Your Content”) remain yours. You retain all intellectual-property rights.

You grant Suelto a non-exclusive, worldwide, royalty-free licence to host, store, transcribe, process and display Your Content solely to provide, maintain and improve the service for you, and to comply with law. This licence ends when Your Content is deleted (subject to §11 retention for backups/invoices). We do not use Your Content to train our own models. Providers we contract for AI processing process Your Content under their own terms: most exclude customer content from model training, and one — Meta’s Muse Spark contributor tier, used only for Writing Lab scenes — is permitted by its terms to use submitted content to improve its models. That is disclosed per provider in the Privacy Policy (§5–§6) rather than as a blanket promise, and it is the reason stories should not contain personal or sensitive details.

You represent that Your Content is lawful and that you have the rights to upload it.

10. Our IP

The service, including its software, design, trademarks (“Suelto” and the bull logo), marketing copy and the generic lesson framework, is owned by or licensed to us and protected by Spanish and EU intellectual-property law. No rights are assigned except the limited, revocable right to use the service for its intended purpose while subscribed. You may not copy, modify or create derivative works of the service except as allowed by mandatory law.

11. Data and privacy

How we handle personal data is described in our Privacy Policy (GDPR + LOPDGDD). The privacy policy forms part of these terms. See there for controller identity, purposes, processors (Cloudflare — including hosting, AI Gateway and the opt-in, cookieless Web Analytics — Anthropic, Meta, ElevenLabs, Stripe, Crisp for the support chat), international transfers, retention and your rights before the AEPD.

Deletion: you may request export or deletion at hola@suelto.es from your account email — we erase learning data and recordings within 30 days (backups within 90 days), retaining only invoices and minimal legal logs per §5 of the Privacy Policy.

12. Warranties and conformity

We provide the service with due diligence and in conformity with the contract. For consumers, the statutory guarantees for digital services under Arts. 119–126 TRLGDCU apply: the service will have the functionality and compatibility described at purchase and will receive necessary updates during the subscription.

Except as mandated by law, the service is otherwise provided “as is”. We do not warrant uninterrupted availability or that every AI output will be error-free.

13. Liability

Nothing in these terms limits liability where limitation is not permitted by law (e.g., intent or gross negligence — dolo o culpa grave — or liability for death, personal injury or consumer protection).

Subject to the preceding paragraph and to the extent permitted by Spanish law: (a) our aggregate liability for paid users is limited to the amount you paid in the 12 months before the event giving rise to the claim; (b) we are not liable for indirect, consequential or lost-profit damages, or for AI hallucinations where the output was clearly not to be relied upon per §8.

14. Changes to the service and terms

We may update the service (features, caps, models, providers) to improve learning or for legal/security reasons. Paid features will not be materially reduced during a prepaid period without a proportionate remedy.

We may update these terms. Material changes are notified by email and in-app at least 14 days before taking effect. Continued use after the effective date constitutes acceptance. If you do not accept material changes, you may cancel before they take effect and retain access through the end of the current period.

15. Term and termination

These terms apply from account creation until termination. You may close your account at any time. We may suspend or terminate for material breach, non-payment, or extended inactivity, after reasonable notice where practicable. Upon termination your right to use the service ceases; §§ 9–11, 13, 16 and accrued payment obligations survive.

16. Governing law and jurisdiction

These terms are governed by Spanish law, including the TRLGDCU, LSSI and the Civil Code, and — where applicable — EU law. For consumers, the mandatory protections of your EU country of residence are not excluded.

Jurisdiction: if you are a consumer with habitual residence in the EU, you may bring proceedings in the courts of your domicile or, at your choice where permitted, before the courts of Alicante, Spain — and we may sue you only in your domicile (Art. 52.2 LEC, Art. R121-3 Code de la consommation analog, Brussels I bis). Business customers submit to the exclusive jurisdiction of the courts of Alicante, Spain.

Complaints & ADR: contact hola@suelto.es first. In Spain you may request an official complaint form (hoja de reclamaciones) and use the consumer arbitration system (Sistema Arbitral de Consumo). EU consumers may also use the European Online Dispute Resolution platform: ec.europa.eu/consumers/odr. We will inform you whether we submit to a specific ADR entity when a dispute arises, as required by Art. 14 ADR Directive / Art. 21 TRLGDCU.

17. General

• Entire agreement: these terms plus the Privacy Policy and any plan-specific checkout terms form the entire agreement for the service.
• Severability: if any clause is held invalid, the rest remains in force; the invalid clause is replaced by a valid one closest to its economic purpose.
• Assignment: you may not assign without consent; we may assign in connection with a reorganisation, merger or asset sale with notice.
• Language: these terms are provided in English for convenience. Spanish law governs interpretation. Where a Spanish translation is published, the Spanish version prevails.

18. Contact

Questions about these terms: hola@suelto.es — subject “Terms” — via suelto.es/contact, or through the support chat widget on suelto.es and in the app (answered by us; messages are delivered via Crisp, see the Privacy Policy). Postal: Legal Iuris La Zenia, C. Salzillo, S/n, 03189 Orihuela, Alicante, Spain.

Model withdrawal form (Annex to TRLGDCU — you may copy and send to hola@suelto.es):
“I hereby notify that I withdraw from my contract for the supply of Suelto (order/subscription on [date], email [your account email]). Name, address, date, signature (if on paper).” We acknowledge receipt promptly.