Complaints Procedure

Last updated: [TBD] · This is a working draft pending legal review.

1. About this procedure

This Complaints Procedure explains how Coded B.V. ("Coded", "we", "us") receives, handles and resolves complaints about its commerce platform and the decisions we make in operating it. It applies to everyone who uses or is affected by the platform, including merchants who run projects on the platform, members and administrators of an Organization, buyers who purchase from a merchant's shop, and any individual or entity that has submitted a report or notice to us.

Coded is an international company operating globally. The Netherlands is our place of registration and our initial launch market, but this procedure is written to apply wherever you are located. Where the law of your own country or jurisdiction grants you mandatory complaint, redress or consumer-protection rights, this procedure operates in addition to those rights and does not limit them.

This procedure sits alongside, and forms part of, our Terms of Service. Where this document refers to "content", "moderation decisions", "account actions" or "statements of reasons", those terms have the meaning given in our Terms of Service and any applicable acceptable-use or content policy.

1.1 Legal framework

This procedure is designed to meet, among other applicable laws, the requirements of:

• the internal complaint-handling obligations applicable to providers of online platforms under the EU Digital Services Act (Regulation (EU) 2022/2065), in particular its provisions on internal complaint handling and statements of reasons;
• the internal complaint-handling obligations applicable to providers of online intermediation services towards their business users under the EU Platform-to-Business Regulation (Regulation (EU) 2019/1150), in particular its provisions on internal complaint handling and mediation; and
• general consumer-protection and contract law applicable to the relationship between Coded and its users.

References to specific regulations are included for transparency. The protections offered here are provided as a matter of Coded policy to all users, including those located outside the European Union, except where a protection is by its nature limited to a specific category of user or jurisdiction.

2. What you can complain about

You may submit a complaint about any of the following:

• Content and moderation decisions — a decision to remove, restrict, disable, demote, age-restrict, label or otherwise act on content, a project, a listing or a catalog item; or, conversely, a decision not to act on content that you have reported to us.
• Account and access actions — a decision to suspend, restrict, downgrade or terminate an Organization, a merchant account, a project, or an individual user's access; a decision to withhold, freeze or delay a payout; or any limitation we place on the use of platform features.
• Service issues — technical faults, outages, payment or fulfilment processing problems, billing or invoicing errors, or other operational failures that directly affect you.
• Conduct of Coded — any other measure we have taken, or behaviour on our part, that relates directly to the provision of the platform and that affects you, including the way we have applied our Terms of Service or policies.
• Reports and notices — the outcome of a report or notice you previously submitted to us about content or behaviour on the platform.

This procedure is not the route for reporting illegal content or abuse in the first instance — for that, see Section 4. Complaints about how a report or notice was handled, however, do fall within this procedure once an initial decision has been made.

2.1 Disputes between buyers and merchants

Coded charges a 0% platform fee and acts as the platform operator, not as the seller of merchants' goods. The contract of sale for goods bought from a shop is between the buyer and the merchant. Disputes about an individual order — such as a refund, a return, a delivery delay or product quality — should first be raised with the merchant directly. You may still complain to Coded where the issue concerns the platform itself (for example a payment-processing fault or a failure of platform policy), and we will route order-level disputes to the relevant merchant and, where appropriate, assist.

3. Who may submit a complaint

Any of the following may use this procedure free of charge:

• merchants and the Organizations and projects they operate;
• members, administrators and authorised representatives of an Organization;
• buyers who have transacted, or attempted to transact, through a shop on the platform; and
• any individual or entity that submitted a report or notice to us, in respect of the decision taken on that report or notice.

There is no charge for submitting or pursuing a complaint under this procedure.

4. How to submit a complaint

4.1 Where to send it

If you are unsure which address to use, send your complaint to support@coded.co and we will route it internally. Sending to the wrong address will not cause your complaint to be rejected or to lose its place in the queue.

4.2 What to include

To help us handle your complaint quickly, please include as much of the following as you can:

1. Your name and contact details, and the role in which you are complaining (merchant, Organization member, buyer, reporter, or other).
2. The Organization, project, account, order or item your complaint concerns, with any reference numbers, URLs or order IDs.
3. A clear description of what happened and what you are complaining about.
4. If your complaint relates to a decision we made: the date of that decision and the reference number or statement of reasons we sent you, if you have it.
5. What outcome you are seeking (for example, reversal of a decision, restoration of content or access, a refund, or a correction).
6. Any supporting evidence, such as screenshots, correspondence or documents.

You may submit a complaint in English. We will make reasonable efforts to handle complaints submitted in the primary language of your launch market where we are able to.

4.3 Reference to the statement of reasons

When we take a content or account action, we issue a statement of reasons that explains the decision, its legal or contractual basis, the role of any automated tools in the decision, and the redress options available to you — including this complaints procedure. If you are complaining about such a decision, quoting the reference number from that statement of reasons lets us locate the case immediately. If you did not receive a statement of reasons, tell us, and we will provide it or explain why one was not issued.

5. How we handle complaints

We handle all complaints in a timely, non-discriminatory, diligent and non-arbitrary manner. We give each complaint due and individual consideration on its merits.

5.1 Human oversight

Decisions on complaints — in particular complaints about content and moderation decisions — are taken under the supervision of appropriately qualified staff and are not taken solely on the basis of automated means. Where automated tools assisted an original decision, a person reviews the complaint about it.

5.2 Acknowledgement and resolution timelines

The timelines below are Coded's service targets. They run from the moment we receive a complaint that contains enough information for us to identify the issue. If we need more information, we will tell you, and the clock for resolution pauses until you respond.

For complaints concerning content or moderation decisions, we will inform you of our reasoned decision without undue delay.

5.3 Our decision

When we reach a decision, we will tell you:

• the outcome and the reasons for it;
• whether we are upholding, partially upholding, or rejecting the complaint;
• where we are reversing an earlier decision (for example, restoring removed content or reinstating access), the action we will take and when; and
• what further options are open to you, including the escalation and out-of-court routes in Sections 6 and 7.

Where a complaint contains sufficient grounds for us to consider that an earlier decision was wrong — for example that content we removed was not in fact illegal or contrary to our Terms, or that the conduct in question did not warrant the action taken — we will reverse that decision without undue delay.

5.4 Access period

For complaints about a content or account decision, you may use this internal complaint-handling system for a period of at least six months following the decision concerned.

6. Escalation within Coded

If you are not satisfied with the outcome, you may ask for the matter to be escalated. Reply to the decision we sent you, or write to legal@coded.eu, stating that you wish to escalate and why. An escalated complaint is reviewed by someone who was not responsible for the original decision. We aim to respond to escalations within 15 business days.

Using the internal escalation route is optional and does not remove or delay any external rights you have under Section 7.

7. Out-of-court dispute resolution and external options

If a complaint cannot be resolved through this procedure, or if you prefer not to use it, the following external options may be available to you. The availability of each depends on your status (consumer, business user) and your jurisdiction.

7.1 Out-of-court dispute settlement (online platforms)

If your complaint concerned a content or moderation decision and you are not satisfied with our decision, you may be entitled to refer the dispute to a certified out-of-court dispute settlement body under the EU Digital Services Act. Such bodies can rule on disputes about our decisions but their decisions are not binding on the parties in the way a court ruling is. We will provide information about the relevant body or bodies in our statement of reasons or on request to report@coded.co. Using an out-of-court body does not prevent you from going to court.

7.2 Mediation for business users (merchants)

For complaints by merchants and other business users that cannot be settled through this internal procedure, Coded is willing to engage in good-faith mediation to settle the dispute out of court, in line with the EU Platform-to-Business Regulation. The mediator(s) Coded is willing to use, and the practical arrangements, are set out in (or will be identified through) our Terms of Service; you may also request these details from legal@coded.eu. Engaging in mediation is without prejudice to either party's right to start legal proceedings.

7.3 Consumers and out-of-court dispute resolution

If you are a consumer, you may in certain cases be entitled to use an alternative dispute resolution (ADR) body to seek an out-of-court resolution, depending on your country of residence and the nature of the dispute. Where ADR applies, the competent body and how to contact it will be identified at the point it is relevant. Consumers should normally first contact the merchant for order-level disputes (see Section 2.1).

7.4 Courts and mandatory rights

Nothing in this procedure removes your right to bring a matter before a competent court, or to use any complaint, redress or dispute-resolution mechanism available to you under the mandatory law of your jurisdiction. The governing law and jurisdiction provisions are set out in our Terms of Service (Netherlands law; the courts of Amsterdam), subject to any mandatory protections of your local law.

8. Good faith, abuse and bad-faith complaints

We ask that complaints be made in good faith and that the information provided be accurate. We may decline to process, or may suspend processing of, complaints that are manifestly unfounded, abusive, repetitive without new grounds, or that are submitted in a manner designed to disrupt the platform — and we will tell you when we do so and why. This does not affect genuine complaints, including repeat complaints supported by new information.

9. Records and data protection

We keep records of complaints and their outcomes so that we can handle them properly, improve the platform, meet our legal obligations and demonstrate compliance. We process personal data submitted in a complaint in accordance with our Privacy Policy. Coded operates on a privacy-by-design basis, uses cookieless analytics, does not sell or share personal data, and hosts platform data in the European Union (Frankfurt, Germany). Questions about how we handle personal data in complaints can be sent to privacy@coded.eu.

10. Changes to this procedure

We may update this procedure from time to time to reflect changes in the platform, our practices or applicable law. When we make material changes, we will update the "last updated" date and, where appropriate, notify affected users. The version in force at the time you submit a complaint applies to that complaint.

Contact

• Complaints about content/moderation and reports of illegal content or abuse: report@coded.co
• Account, service, billing and general complaints: support@coded.co
• Escalation, mediation and legal matters: legal@coded.eu
• Data protection and privacy questions: privacy@coded.eu
• Security vulnerabilities: security@coded.co

Coded B.V., a private limited company registered in the Netherlands (a subsidiary of Coded Holding B.V.).

• Registered address: De Taling 15, 2761 SL Zevenhuizen, The Netherlands
• Dutch Chamber of Commerce (KvK) number: 42027097
• VAT number: NL869368795B01
• Managing director: Ibrahim Mohamed
• Effective date of this procedure: 11 June 2026