Refund & Returns Policy

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

1. About this Policy

Coded B.V. ("Coded", "we", "us", "our"), a private limited company registered in the Netherlands (a subsidiary of Coded Holding B.V.), operates a commerce platform on which a merchant runs one or more branded online shops ("projects"), supported by a curated product catalog, built-in payments, and built-in fulfilment.

This Policy explains how returns and refunds work for purchases made through projects published on the Coded platform. It describes the respective roles of Coded, the merchant, and the buyer; the statutory rights that may apply to a buyer; and the process by which a return is requested and a refund is routed.

This Policy applies worldwide. Coded is an international company; the Netherlands is our place of registration and our initial launch market, and our platform serves merchants and their buyers across many jurisdictions. Mandatory consumer-protection law of the buyer's own jurisdiction may grant rights that go beyond this Policy, and nothing in this Policy limits or waives those mandatory rights (see Section 11).

1.1 Who this Policy is for

• Buyers — people and businesses who purchase products from a merchant's project. This Policy tells you what rights you have, who is responsible for your purchase, and how to request a return or refund.
• Merchants — the seller of record for every transaction made through their project. This Policy sets out the minimum standards a merchant's own refund policy must meet, and how Coded supports the return and refund process.

This Policy works together with the Coded Terms of Service, the Privacy Policy, and any additional terms a merchant publishes on their own project. Where a merchant's published policy conflicts with the mandatory minimums in this Policy or with applicable law, the more protective standard for the buyer prevails.

2. Roles and responsibilities

Understanding who is responsible for a purchase is the foundation of this Policy.

2.1 The merchant is the seller

The merchant is the seller of record for every product sold through their project. The contract of sale for a product is between the buyer and the merchant. The merchant is responsible for:

• describing products accurately and setting prices, taxes, and shipping terms;
• setting a returns and refunds policy that meets at least the minimum standards in this Policy and complies with all law applicable to the merchant and to the buyer;
• accepting valid returns, honouring statutory withdrawal and conformity rights, and authorising refunds;
• handling buyer enquiries and complaints about products, delivery, and returns.

2.2 Coded provides the platform

Coded provides the technology platform, the curated catalog, and the built-in payments and fulfilment infrastructure that merchants use to operate their projects. Coded is not the seller of the products offered through a project and is not party to the sales contract between a buyer and a merchant, except where Coded itself is identified as the seller of a specific item.

Coded's role in returns and refunds is operational and facilitative. Coded:

• enforces the minimum standards set out in this Policy as a condition of using the platform;
• provides the tooling through which a merchant receives return requests and issues refunds;
• routes authorised refunds back to the buyer through the original payment processor (see Section 8);
• may, at its discretion or where required by law or by a payment processor, intervene in a dispute (see Section 9).

2.3 No platform fee on transactions

Coded charges merchants a 0% platform fee on payment transactions. A merchant pays only the pass-through processing cost charged by the payment processor (Stripe or Mollie). Because Coded does not take a transaction fee, no Coded transaction fee is ever withheld from, or netted against, a refund. Subscription fees a merchant pays to publish a project are separate from transaction processing and are addressed in the Terms of Service.

3. Buyer statutory rights overview

Depending on where the buyer is located and the nature of the purchase, mandatory law may grant the buyer rights that exist independently of any merchant policy. This Section is a general, international summary; the buyer's own jurisdiction governs the precise scope and any exceptions. Where statutory rights apply, they sit on top of — and are never reduced by — a merchant's voluntary returns policy.

3.1 Right of withdrawal / cooling-off (EU and EEA, and comparable regimes)

For consumer purchases of goods made at a distance (for example, online) from a merchant acting in a business capacity, EU and EEA consumer law generally grants a 14-day right of withdrawal. Within this period a consumer may withdraw from the contract without giving any reason. Comparable cooling-off or distance-selling rights exist in a number of other jurisdictions (for example, the United Kingdom and parts of the Asia-Pacific region), often with their own periods and conditions.

Key features of the EU/EEA right of withdrawal, summarised:

• The period is normally 14 days. For goods, it generally starts the day the consumer (or a third party indicated by the consumer) takes physical possession of the goods; for an order of multiple goods delivered separately, it generally starts on receipt of the last item.
• No reason is required, and the right does not depend on the goods being defective.
• Notification. The consumer informs the merchant of the decision to withdraw (a clear statement, or the model withdrawal form where provided) within the period.
• Return of goods. The consumer returns the goods without undue delay, normally within 14 days of giving notice.
• Refund timing. The merchant reimburses the consumer without undue delay and no later than 14 days after being informed of the withdrawal. The merchant may withhold reimbursement until the goods are received back or the consumer supplies proof of return, whichever is earlier.
• What is reimbursed. The price of the goods plus the standard (least expensive) outbound delivery cost. Supplementary delivery costs chosen by the consumer (for example, express shipping) need not be reimbursed.
• Return shipping cost. The consumer may bear the cost of returning the goods only if the merchant informed the consumer of this before purchase; otherwise the merchant bears it.
• Diminished value. The consumer is liable for any diminished value of the goods resulting from handling beyond what is necessary to establish their nature, characteristics, and functioning.

3.2 Legal guarantee of conformity (defective or non-conforming goods)

Separately from any withdrawal right, EU/EEA law and many other regimes give consumers a legal guarantee that goods conform to the contract (for example, in the EU, generally for at least two years from delivery). If goods are faulty, not as described, or not fit for purpose, the consumer is normally entitled to repair, replacement, a price reduction, or a refund, depending on the circumstances and the law that applies. This right is not time-limited to a cooling-off window and exists even where no withdrawal right applies.

3.3 United States — state consumer law

The United States has no single federal mandatory return right for most goods; return rights are typically a matter of the seller's stated policy and applicable state law. State law may require that a seller's return and refund policy be clearly disclosed (and, in some states, that the absence of refunds be conspicuously posted, failing which a refund may be required). Buyers may also have remedies for misrepresentation, defective goods, or unauthorised charges under state and federal law. Where a merchant directs goods or services to buyers in a US state, the merchant's policy must comply with that state's disclosure and refund requirements. Privacy rights connected to a return (for example, access to or deletion of data) are addressed in the Privacy Policy.

3.4 General international framing

Where a buyer is located in a jurisdiction not specifically described above, the mandatory consumer law of that jurisdiction applies to the extent it cannot be excluded by contract. This Policy is intended to be read as granting the buyer whichever protection is greater: the merchant's published policy, the standards in this Policy, or the buyer's mandatory local law.

4. Merchant policy requirements (platform minimum standards)

As a condition of publishing a project on the Coded platform, a merchant must maintain and prominently display a returns and refunds policy that, at a minimum:

• complies with all applicable law, including the buyer's mandatory consumer-protection law, and never purports to exclude or limit a buyer's statutory rights;
• clearly discloses, before purchase, the return window, the condition in which items must be returned, who bears return shipping costs, any restocking fee permitted by law, and any categories the merchant treats as non-returnable (see Section 6);
• honours the statutory withdrawal / cooling-off right and the legal guarantee of conformity wherever they apply, regardless of the merchant's voluntary policy;
• processes refunds promptly, within statutory deadlines where they apply and otherwise within the timeframe stated in the merchant's policy;
• routes refunds through the original payment method via the platform's payment processors, consistent with Section 8;
• does not misrepresent the buyer's rights or the existence, scope, or conditions of returns.

A merchant policy may be more generous than these minimums (for example, a longer return window, free return shipping, or accepting returns of items law would allow it to refuse). It may not be less protective than the applicable mandatory law or the minimums above. Coded may suspend or remove a project whose policy or conduct falls below these standards.

5. How to request a return or refund

5.1 Contact the merchant first

Because the merchant is the seller, a return or refund request normally starts with the merchant that operates the project from which the purchase was made. The merchant's published policy will set out how to make a request and the information required (typically the order reference, the items concerned, and the reason where one is needed). For a statutory withdrawal, no reason is required.

5.2 Standard process

1. Open a request. Notify the merchant within the applicable window — the statutory period where one applies, or the merchant's published window otherwise. A clear written statement is sufficient; where a model withdrawal form is provided, you may use it.
2. Authorisation. The merchant confirms the request and, where a physical item is involved, provides return instructions and any return-shipping arrangement.
3. Return the item. Send the item back as instructed, in the required condition, within the applicable return window. Keep proof of return.
4. Inspection. On receipt, the merchant verifies the item against the agreed condition (subject to the buyer's right to handle goods enough to establish their nature, characteristics, and functioning).
5. Refund. The merchant authorises the refund, which is routed back to the original payment method through the payment processor (see Section 8).

5.3 Where Coded can help

If a buyer cannot reach a merchant, or believes a merchant is not honouring its policy or the buyer's statutory rights, the buyer may contact Coded at support@coded.co. Coded can provide the merchant's contact and seller details, facilitate communication, and, where appropriate, take the steps described in Section 9. Coded's ability to assist does not make Coded the seller or a party to the sales contract.

6. Non-returnable categories

Applicable law permits a merchant to exclude certain items from voluntary returns and, in defined cases, from the statutory withdrawal right. Where the EU/EEA right of withdrawal applies, the law itself lists categories that may be excluded. A merchant's published policy must state which of these it relies on, and a merchant may not invent exclusions beyond what law allows. Commonly recognised non-returnable or withdrawal-exempt categories include:

• Custom or personalised goods made to the buyer's specifications or clearly personalised.
• Perishable goods or goods that deteriorate or expire rapidly.
• Sealed goods unsuitable for return for health-protection or hygiene reasons that have been unsealed after delivery.
• Goods inseparably mixed with other items after delivery.
• Sealed audio, video, or software that has been unsealed after delivery.
• Newspapers, periodicals, or magazines (other than subscription contracts).
• Goods made urgent by price fluctuations outside the merchant's control on financial markets.

These exclusions never override the legal guarantee of conformity: even an item that cannot be withdrawn for "change of mind" reasons can be returned, repaired, replaced, or refunded if it arrives faulty, damaged, or not as described. A merchant must disclose any non-returnable category clearly before purchase; an undisclosed exclusion is not enforceable against the buyer.

7. Condition of returned items, return shipping, and fees

7.1 Condition

Items returned under a voluntary policy must normally be in the condition the merchant's policy requires (for example, unused and in original packaging). Where the statutory withdrawal right applies, the buyer may handle and inspect the goods as they would in a shop; the merchant may reduce the refund only to reflect a genuine diminished value caused by handling that went beyond establishing the goods' nature, characteristics, and functioning.

7.2 Return shipping

Who pays return shipping depends on the reason for the return and applicable law:

• Faulty, damaged, or not-as-described items: the merchant bears the cost of return.
• Statutory withdrawal (change of mind): the buyer may bear the return cost only if the merchant disclosed this before purchase; otherwise the merchant bears it.
• Voluntary returns outside any statutory right: as stated in the merchant's published policy.

7.3 Restocking and other fees

A merchant may charge a restocking fee only where law allows it and only where the fee was clearly disclosed before purchase. No restocking fee may be applied to a faulty item or to a valid exercise of a statutory withdrawal or conformity right where law prohibits it. Coded does not charge any fee on a refund.

8. How refunds are processed

8.1 Routing through the original payment method

Refunds are routed back to the original payment method through the payment processor used for the purchase — Stripe or Mollie. This is both a legal expectation in many jurisdictions and the technical default of the platform. If a refund cannot be returned to the original method (for example, an expired card or a closed account), the merchant will arrange an alternative method permitted by law, with the buyer's agreement where required.

8.2 Amount refunded

A refund covers the amount required by the applicable right or by the merchant's policy — typically the price of the returned item and, for a statutory withdrawal, the standard outbound delivery cost, subject to any lawful and pre-disclosed deduction (for example, diminished value or a permitted restocking fee). Because Coded charges no platform transaction fee, no Coded fee is deducted from a refund. Pass-through payment-processing costs are handled in accordance with the processor's rules and the merchant's agreement; they do not reduce the buyer's statutory entitlement where law requires a full refund.

8.3 Timing

Where a statutory deadline applies (for example, the EU/EEA rule to reimburse without undue delay and no later than 14 days after being informed of a withdrawal), the merchant meets that deadline. Where no statutory deadline applies, the merchant refunds within the time stated in its published policy. After a refund is authorised and submitted to the processor, the time for the funds to appear depends on the processor and the buyer's bank or card issuer and is outside Coded's and the merchant's direct control.

8.4 Currency and conversion

Refunds are normally issued in the currency of the original transaction. Where currency conversion occurred, exchange-rate movement between purchase and refund, and any conversion fee charged by the buyer's bank or card issuer, are determined by those third parties and are not set or controlled by Coded.

9. Disputes, chargebacks, and Coded intervention

If a buyer and merchant cannot resolve a return or refund, the following may apply:

• Coded facilitation. Coded may review the matter, request information from both sides, and help the parties reach a resolution. Coded may, where a merchant has clearly failed to honour the buyer's rights or this Policy, take action against the merchant's account, including authorising or directing a refund through the processor and suspending or removing the project.
• Chargebacks. A buyer may have the right to ask their bank or card issuer to reverse a charge. Chargebacks are governed by the rules of the relevant card scheme or processor (Stripe or Mollie) and the buyer's bank, not by Coded.
• EU online dispute resolution and alternative dispute resolution. Buyers in the EU may have access to out-of-court dispute-resolution mechanisms; where applicable, the merchant will provide the relevant details.
• Regulators and courts. Nothing in this Policy prevents a buyer from contacting a consumer-protection authority or bringing a claim in a competent court under applicable law (see Section 10).

10. Governing law and jurisdiction

This Policy, and any dispute between a buyer and Coded arising out of it, are governed by the law of the Netherlands, and the courts of Amsterdam, the Netherlands have jurisdiction — except that this choice does not deprive a buyer who is a consumer of the protection of mandatory provisions of the law of the buyer's country of habitual residence, and a consumer may also be entitled to bring or defend proceedings in the courts of that country where applicable law so provides. The sales contract itself is between the buyer and the merchant and may be governed by its own terms and by the buyer's mandatory local law.

11. Relationship to mandatory rights and to other terms

This Policy does not limit, exclude, or waive any right a buyer has under mandatory consumer-protection or data-protection law. Where any term of this Policy conflicts with such mandatory law, the mandatory law prevails and the remainder of this Policy continues to apply. Where a merchant's published policy and this Policy differ, the standard more protective of the buyer applies. Personal data handled in connection with a return or refund is processed in line with the Privacy Policy; the platform's data is hosted in the EU (Frankfurt).

12. Changes to this Policy

We may update this Policy from time to time, for example to reflect changes in law, the platform, or our processes. The current version is always available at this page, with its effective date shown above. Material changes take effect on the stated effective date; continued use of the platform after that date constitutes acceptance of the updated Policy, subject to any mandatory notice rights a buyer or merchant has under applicable law.

Contact

For questions about this Policy, or to escalate a return or refund issue you cannot resolve with a merchant, contact:

• Buyer and general support: support@coded.co
• Legal: legal@coded.eu

Coded B.V. Registered office: De Taling 15, 2761 SL Zevenhuizen, The Netherlands Netherlands Chamber of Commerce (KvK) number: 42027097 VAT number: NL869368795B01 Effective date: 11 June 2026