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Online school legal docs: terms of sale, privacy policy, refunds

An online school sells with no paper contract, no stamp and no office. So the paperwork gets postponed — until the first chargeback, a student complaint, or an email from the payment provider asking for your terms of sale. Three documents close most of the risk: the public offer (terms of sale), the privacy policy and the refund policy.

A disclaimer up front: this is not legal advice. A lawyer should review the final texts, and an accountant should handle tax and receipts. But with a ready structure, a lawyer's work costs a fraction of "please write something from scratch".

1. Terms of sale — the main document

Under Ukrainian e-commerce law, the contract is concluded the moment the buyer accepts your offer: ticks "I agree with the terms" and clicks "Pay". Payment equals signature. So the terms must be available before checkout, not buried in the footer afterwards.

What to include:

  • Who the seller is. Legal name, registration number, address, support email.
  • What exactly you sell. Not "access to knowledge" but specifics: number of lessons, format (recorded or live cohort), whether homework review is included.
  • Price and payment terms. Currency, payment methods, instalments, VAT.
  • When access starts. Immediately after payment or on the cohort start date — the single most common source of disputes.
  • How long access lasts. "Lifetime" is a dangerous word: close the school and you breach your own terms. Say 12 months, 24 months, or "for as long as the course exists on the platform".
  • Content rights. Materials are for personal, non-commercial use; screen recording, resale and distribution are prohibited.
  • Grounds for blocking. When you may revoke access without a refund: shared logins, leaked materials.
  • Force majeure and changes. For a Ukrainian audience this is not boilerplate — describe upfront what happens if a cohort is postponed because of air raids or power cuts.

Add one clause explicitly: "The contract is concluded at the moment of payment. Payment confirms that the buyer has read these terms." That is your signature.

2. Privacy policy

You collect names, emails, phone numbers, sometimes Telegram IDs and payment records. That is personal data — Ukrainian data protection law applies, and GDPR too if any of your students are in the EU.

Minimum contents:

  • what data you collect and why;
  • your legal basis — consent plus performance of the contract;
  • who you share it with: payment provider, email service, hosting, analytics (categories are enough);
  • how long you keep it after the course ends;
  • how a person deletes their account and where to send the request;
  • a separate section on cookies and ad pixels.

One practical detail: marketing consent must be a separate, unticked checkbox. That is not only the law — mailbox providers also judge list quality when deciding between the inbox and spam.

3. Refund policy

The hardest one. Course access is a service, not a physical good, so the familiar 14-day return rule does not apply directly. You set the terms yourself — but they must be specific and something you will actually honour.

Three workable models:

  1. 7–14 day no-questions guarantee. Converts cold traffic best. Cost: a few percent of refunds — build it into your unit economics.
  2. Conditional guarantee. Refund if the student completed the first N lessons, submitted homework and still got no result. Platform progress becomes the evidence.
  3. Pro-rata refund. Minus the value of the completed portion — typical for long programmes and instalments.

Always specify: the deadline for requests, the channel (email to one specific address, not DMs), the review period, the refund method (same card), and the cases where the guarantee does not apply.

And chargebacks. If a student goes to their bank instead of you, your defence is stored evidence: login records, lesson progress, correspondence, proof the terms were shown before payment. A school that keeps everything in private chats usually loses that dispute.

4. Receipts and acquiring

Card payments require a fiscal receipt — a digital product does not exempt you. In practice this means either a software cash register or fiscalisation on the payment provider's side. Confirm it with your acquirer before you launch sales. Turnover limits for your tax bracket and the applicable rate should be checked with an accountant; those numbers change.

5. A one-day checklist

  • Publish /terms, /privacy and /refund pages on your own domain.
  • Link them in the site footer and in checkout — above the pay button.
  • Add unticked consent checkboxes to checkout and signup forms.
  • Set up a dedicated email for legal requests and actually read it.
  • Date each revision and archive previous versions.
  • Send the draft to a lawyer for review.

Archived versions matter: if a student bought a year ago under different terms, the dispute runs on the version they accepted then.

What this looks like on a platform

The hard part is not writing the text — it is having the evidence when you need it. In CREO, terms and policy pages are built in the sales page builder, payments run through WayForPay and Stripe, and leads, payments and correspondence live in the CRM, so a student's history does not have to be reconstructed from screenshots. Lesson progress adds another argument to the "I never opened anything, give me my money back" conversation: schools that turn gamification on keep completion at 70–80%. Over 100,000 students already use the platform, and support replies in about 15 minutes on average.

CREO beta testing starts in August 2026 — join the early list at platform.creo.ua.

FAQ

Can I copy another school's terms and change the name?

The most common mistake. First, you inherit someone else's access, guarantee and blocking rules, which may not match your product — and in a dispute you have to honour exactly those. Second, the text itself is a protected work. Use another school's document as a structural example, but write the wording for your own course.

Is a refund guarantee mandatory?

There is no requirement to guarantee refunds on a service, but there is a requirement to state your selling terms clearly. If you offer no refunds at all, say so in the policy — before checkout and not in fine print. Silence is worse than a plain no: the student goes to the bank for a chargeback, and your position there is weaker.

A student finished the whole course and demands a refund. What now?

This is exactly why the policy needs a request deadline and guarantee conditions. If the deadline has passed and progress shows the material was completed, you have factual grounds to decline — provided those rules were in the terms at the time of payment. Keep progress logs, the payment record and the correspondence: in a chargeback the bank looks at precisely those.

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By Віталій Вальков

Засновник CREO

Засновник CREO — української AI-first платформи для онлайн-шкіл.