Refund policy

Effective date: 12 May 2026

Location: swishandclick.eu/policies/refund-policy

Linked from: the storefront checkout and from Part 12 of the v2 General Terms of Service

Subject company

Swish and Click OÜ
Registered office: Lõõtsa tn 5, 11415 Tallinn, Estonia
Estonian commercial register number: 17301303
EU VAT number: EE102889941
Email: info@swishandclick.eu
Phone: +39 353 202 5915
Website: swishandclick.eu

Other addresses associated with Swish and Click OÜ — including the Spanish virtual correspondence address at Gran Via de les Corts Catalanes 672, 08010 Barcelona, Spain, and any other coworking, mail-handling or virtual-office addresses in Italy, Germany, Switzerland, the United Kingdom or elsewhere — are correspondence and mail-handling facilities only. Unless mandatory local law expressly determines otherwise, those addresses are not intended to constitute branches, registered offices, warehouses, operational offices, permanent establishments, places of effective management, tax establishments or addresses for service of legal proceedings. The sole legal domicile of Swish and Click OÜ is Lõõtsa tn 5, 11415 Tallinn, Estonia.

Position statement

Swish and Click OÜ is an Estonian-registered business-to-business (B2B) distributor and sourcing partner of promotional products, branded merchandise, customised apparel, printed goods, corporate gifts, electronics, drinkware, bags, notebooks, textiles, recycled merchandise and multi-country merchandising campaigns. We work through a network of third-party suppliers, manufacturers, decorators, printers, embroiderers, engravers, freight forwarders and couriers.

This Returns and Refunds Policy is deliberately a hard B2B policy. Custom Goods are generally non-returnable. Defective, damaged and non-conforming Goods are covered under the strict process set out below. Mandatory consumer rights, where they apply, are fully preserved as carve-outs from the B2B default. A disciplined Goodwill Resolution tier is available at our discretion. This Policy operates alongside, and is subject to, the v2 General Terms of Service ("v2 ToS") and the Cancellation Fee Policy (Part 11 of the v2 ToS).

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1. Definitions and scope

In this Policy, capitalised terms have the meanings set out in the v2 ToS. The following terms are reproduced and supplemented here for ease of use:

This Policy applies to all Orders placed with Swish and Click OÜ via the storefront at swishandclick.eu, via email, via account managers or via any other channel. It applies regardless of the Client's location, subject to mandatory consumer-protection rules of the Consumer's home jurisdiction.

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2. Document hierarchy and relationship to the v2 Terms of Service and Cancellation Fee Policy

In the event of any inconsistency between this Policy and any other document, the order of priority is that set out in the v2 ToS:

1. signed agreement (if any);
2. Order Confirmation;
3. Quotation;
4. approved Proof / Approved Control Sample;
5. Cancellation Fee Policy (Part 11 of the v2 ToS);
6. Urgent Order Disclaimer (where applicable);
7. this Returns and Refunds Policy and the v2 General Terms of Service;
8. website and product-page descriptions;
9. casual emails, WhatsApp messages and verbal sales comments.

This Policy governs post-delivery scenarios (defective, damaged, non-conforming, shortage, late delivery, consumer cooling-off where applicable). Pre-delivery cancellations are governed by the Cancellation Fee Policy (Part 11 of the v2 ToS) and are not the subject of this Policy.

The liability limitations and exclusions in clauses 40–41 of the v2 ToS (the two-tier Kardinalpflichten-safe cap, with mandatory carve-outs for fraud, intent, gross negligence, death or personal injury, and mandatory product-liability statute liability) apply to remedies under this Policy.

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3. General position: Custom Goods are generally non-returnable

3.1 The non-returnability rule

Custom Goods supplied by Swish and Click OÜ are made to the Client's specifications or clearly personalised within the meaning of:

• Article 16(c) of Directive 2011/83/EU (the EU Consumer Rights Directive), which excludes such goods from the consumer right of withdrawal; and
• Regulation 28(1)(b) of the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (SI 2013/3134) in the United Kingdom.

Article 16(c) / Reg 28(1)(b) personalised-goods exemption

Where the Goods are supplied to the Client's specifications or are clearly personalised — which is the default for promotional, branded, decorated and customised merchandise sourced by Swish and Click OÜ — the right to withdraw and the right to return for change of mind do not apply, regardless of whether the Client is acting as a B2B Client or as a Consumer. This exemption is mandatory EU/UK consumer law and is not a contractual term we have introduced. It applies from the moment production tooling, decoration set-up, plate-making, screen-burning, embroidery digitisation, laser-file generation, sublimation print or any equivalent production step is commenced or committed.

3.2 No returns for non-defect reasons

Subject only to the consumer rights expressly preserved at clause 4 and to the Goodwill Resolution tier at clause 9, no return, refund, credit, replacement, reprint or price reduction will be given for any of the following reasons, which are not defects or non-conformities:

• buyer's remorse, change of mind or "we ordered too many";
• end-client refusal, end-client cancellation or end-client downstream rejection;
• campaign failure, event cancellation, postponement or low engagement;
• late internal approval, late stakeholder sign-off or post-production design changes;
• internal stakeholder objection (marketing, legal, compliance, brand, procurement, sustainability) raised after the Proof was approved;
• taste, preference, "we wanted a different feel", subjective aesthetic disappointment;
• variations within Industry Tolerances (clause 3.3);
• factors outside Swish and Click OÜ's reasonable control (force majeure, customs, carrier delay not amounting to fundamental breach);
• any other reason unrelated to a defect, non-conformity, damage in transit, shortage or late delivery amounting to fundamental breach.

3.3 Industry Tolerances — variation within tolerance is not a defect

The following tolerances are customary in the promotional-products, branded-merchandise and decoration industry and apply automatically to all Orders unless expressly modified in writing in the Order Confirmation:

Variations falling within these tolerances are not defects and are not Non-Conformities. They do not give rise to any right of return, refund, credit, replacement or reprint under this Policy.

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4. Consumer rights — carve-out

Mandatory Consumer Rights — Carve-out box

If the Client is a Consumer (a natural person acting outside trade, business, craft or profession), the following mandatory rights apply notwithstanding anything else in this Policy:

• EU 14-day cooling-off (Article 9 CRD): A 14-day right of withdrawal applies to off-premises and distance contracts for non-personalised stock items. It does not apply to Custom Goods, by force of Article 16(c) CRD (and Reg 28(1)(b) CCR 2013 in the United Kingdom).
• Article 11a CRD electronic withdrawal function (the "withdrawal button"): From 19 June 2026, where the right of withdrawal applies and the contract is concluded online, Consumers may exercise it through the dedicated two-step withdrawal function available on the storefront. The function does not extend the right of withdrawal to Goods that fall within the Article 16(c) exemption. Hogan LovellsHogan Lovells
• Spain — Royal Decree-Law 7/2021 (in force 1 January 2022) amending the TRLGDCU: Consumers benefit from a 3-year statutory conformity guarantee from delivery, a 2-year presumption of pre-existing non-conformity, a 5-year limitation period running from manifestation of the non-conformity, and a tiered remedy of repair/replacement → price reduction or termination. Osborne ClarkeCuatrecasas
• France — Code de la consommation Articles L. 217-3 et seq. and the AGEC Law: Consumers benefit from the garantie légale de conformité of 2 years from delivery, with a 24-month presumption of non-conformity, and a 6-month extension of the legal guarantee after repair under Article L. 217-13 (as inserted by the AGEC Law of 10 February 2020), or full renewal of the 2-year period in the event of replacement. Zerowastefrance + 2
• United Kingdom — Consumer Rights Act 2015 (as amended, including by the Digital Markets, Competition and Consumers Act 2024 in force from 6 April 2025): Consumers benefit from the 30-day short-term right to reject faulty goods for a full refund, the right to repair or replacement, the right to a price reduction, and the final right to reject, with refunds payable within 14 days of agreement and the trader bearing return costs for non-conforming goods. House of Commons LibraryMyLawyer
• Estonia — Law of Obligations Act (Võlaõigusseadus), Chapter 11: Consumers may rely on the legal remedies for non-conformity within a reasonable time (mõistlik aeg); the trader must respond to a written complaint within 15 days; the presumption of pre-existing non-conformity is one year from delivery. WIPO LexSorainen
• Switzerland — Swiss Code of Obligations Articles 197–210: Warranty rights apply; for movable goods not incorporated into immovable works, the buyer must inspect on receipt and notify defects promptly. There is no general 14-day distance-selling cooling-off in Swiss law. Iclg
• Other EU Member States: The mandatory consumer-protection rules of the Consumer's home Member State apply where they are more favourable than Estonian law, in accordance with Article 6 of Regulation (EC) No 593/2008 (Rome I).

Where a Consumer's home-state rules grant a free choice between repair and replacement, that choice is preserved and overrides the Swish and Click choice of remedy at clause 6.1.

To exercise the right of withdrawal where it applies, Consumers should use the Article 11a withdrawal function on the storefront (available from 19 June 2026 onwards), or alternatively send an unequivocal statement of withdrawal to logistics@swishandclick.eu.

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5. Defective, damaged or non-conforming Goods — strict process

The remedies in this clause 5 are available only where the strict process is followed in full. Where the Client is a Consumer, the Consumer's mandatory rights at clause 4 take precedence to the extent of any conflict.

5.1 Apparent Defects — 5 Business Days written notice

Apparent Defects (including visibly wrong decoration, wrong colour at first glance, wrong product, missing components, mislabelled packaging or any other defect reasonably discoverable on normal inspection) must be notified in writing to logistics@swishandclick.eu within 5 Business Days of delivery. After 5 Business Days, Apparent Defects are deemed waived, save where mandatory law (including Consumer rights at clause 4) requires otherwise.

5.2 Latent Defects — prompt notice on discovery; long-stop

Latent Defects must be notified in writing promptly upon discovery and in any event within a long-stop of 6 months from delivery, or the duration of the upstream supplier's warranty (whichever is shorter), subject to mandatory law. Mandatory consumer guarantee periods (Spain 3 years; France 2 years + AGEC 6-month repair extension; UK 6 years for breach of CRA implied terms in England, Wales and Northern Ireland, and 5 years in Scotland; Estonia 2 years; Switzerland 2 years for movable goods) are preserved where they apply.

5.3 Shortages and incorrect deliveries — 5 Business Days

Shortages (over and above the ±10% Industry Tolerance) and wholly incorrect deliveries must be notified in writing within 5 Business Days of delivery, with supporting carrier documentation, weighing/counting evidence and photographs.

5.4 Damage in transit — note on PoD and notify within 5 Business Days

Where Goods arrive visibly damaged or with damaged packaging, the Client must:

• annotate the carrier's Proof of Delivery at the point of receipt with a clear written reservation (e.g. "received damaged — 3 cartons crushed — subject to inspection");
• photograph the outer packaging, pallet, shrink-wrap, seals and any visible damage before opening;
• notify Swish and Click OÜ in writing within 5 Business Days.

Acceptance of a delivery without reservation on the PoD will materially weaken — and may in some carrier regimes extinguish — the claim against the carrier and may proportionately reduce the Client's remedy under this Policy.

5.5 RMA requirement — no return without an RMA

No Goods may be returned without a prior written RMA number issued by Swish and Click OÜ. Returns without an RMA will be refused at the receiving location and either (i) returned to the Client at the Client's cost, or (ii) held pending instruction at the Client's cost and risk. The RMA number must be visibly marked on the outside of each returned carton and quoted in all related correspondence.

5.6 Evidence requirements

A valid claim must be supported by all of the following, to the extent applicable:

• clear photographs (minimum 5, including overview, defect close-up, and packaging/label);
• video where the defect is operational, dimensional, structural or only visible in use;
• the affected serial number, lot number, batch code and/or decoration reference;
• a representative physical sample of the defective Goods on request;
• a copy of the relevant Order Confirmation, Proof and Approved Control Sample;
• a copy of the carrier PoD where transit damage is alleged.

5.7 No further use, distribution, on-sale, decoration or modification

From the moment a defect is identified (or should reasonably have been identified) the Client must not:

• use the Goods further;
• distribute, gift, donate or otherwise transfer the Goods to its end-client or any third party;
• on-sell, list for sale or release the Goods into any sales channel;
• decorate, re-decorate, re-label, repackage, alter, repair, modify or relabel the Goods;
• combine the Goods with other goods or assemble them into kits.

Any further use, distribution, on-sale, modification or decoration after a defect is or should have been identified shifts all related risk and loss to the Client and may extinguish the remedy under this Policy.

5.8 Goods to be retained in original packaging

The Client must retain the affected Goods in their original packaging (or, where the original packaging has been opened, in packaging of an equivalent protective standard), in dry, secure storage and away from heat, sunlight and humidity, until Swish and Click OÜ confirms in writing the next step (inspection, collection, photographic-only review, or write-off in place).

5.9 Supplier inspection — upstream lead times

The promotional-products industry runs on a third-party supplier model. Many remedy decisions depend on the upstream supplier's inspection conclusion. Far East-sourced Goods, in particular, may require a physical sample to be returned to Asia for laboratory or QC inspection, and the supplier's inspection lead time can be material (typically 2–8 weeks). Swish and Click OÜ will keep the Client reasonably informed and will not unreasonably delay a remedy, but Clients should expect a realistic timeline where supplier inspection is required.

5.10 Outcome notification within a reasonable time

Swish and Click OÜ will confirm the outcome of the claim — acceptance, partial acceptance, request for further evidence, or rejection with reasons — in writing within a reasonable time having regard to the supplier inspection process. For Consumers, the 15-day response window under Estonian consumer-protection law and equivalent home-state windows apply where they are mandatory. WIPO Lex

5.11 Client liability where Goods were used after defect identified

Where Goods were used, distributed, on-sold, decorated or modified after a defect was identified or should reasonably have been identified, the Client bears the consequential liability and the remedy under this Policy is reduced or extinguished accordingly.

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6. Remedies — hierarchy and limits

6.1 Swish and Click choice of remedy

Subject to clause 4 (where a Consumer's mandatory rights apply), Swish and Click OÜ chooses the remedy from the following hierarchy, applying the principle of proportionality and seeking the least disruptive commercial outcome:

Where mandatory consumer law gives a Consumer a free choice between repair and replacement (notably the EU sale-of-goods regime as transposed in Spain, France and other Member States, and the UK Consumer Rights Act 2015 first-tier remedies), that free choice is preserved and prevails.

6.2 Cap on remedies

Remedies under this Policy are capped at the value of the affected Goods (net of VAT and excluding any retroactive volume rebates) plus reasonable direct costs (such as agreed return-shipping, agreed relabelling and any agreed agreed re-decoration of the replaced subset). Indirect, consequential, incidental, reputational, end-client compensation, lost-profit, lost-campaign and lost-event losses are excluded, subject to clauses 40–41 of the v2 ToS (two-tier Kardinalpflichten-safe cap) and to mandatory carve-outs for fraud, intent, gross negligence, death/personal injury and mandatory product-liability statute liability.

6.3 No indirect or consequential loss

For the avoidance of doubt, and consistent with clauses 40–41 of the v2 ToS, in no event shall Swish and Click OÜ be liable for loss of profit, loss of revenue, loss of business, loss of contracts, loss of goodwill, loss of anticipated savings, loss of data, end-client compensation, third-party fines, or any indirect, special or consequential loss, except to the extent that such liability cannot lawfully be excluded.

6.4 Refund method and timing

Where a refund is approved, it will be paid by the same method as the original payment, within 14 days of approval of the refund, save where the Client requests a different method and Swish and Click OÜ agrees. Refunds to a different bank account, different card or different beneficiary require additional KYC verification and may take longer. MyLawyer

6.5 Currency, bank fees, FX losses

Refunds are paid in the currency in which the original payment was made. Bank fees, intermediary correspondent-bank charges, card-network FX margin, and currency-conversion losses arising from exchange-rate movements between payment and refund are at the Client's cost. Swish and Click OÜ does not compensate for exchange-rate movements.

6.6 Partial refunds for cosmetic / minor defects

Where a partial refund is offered for cosmetic or minor defects (e.g. a small subset of mis-aligned decoration within the same production run), the discount percentage is evaluated case-by-case by reference to (i) the proportion of the run affected, (ii) the materiality of the defect, (iii) the residual end-use value of the affected Goods, and (iv) whether the Goods can still reasonably be used by the Client. Swish and Click OÜ will set out the methodology in writing where requested under clause 11.

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7. Returns logistics

7.1 RMA process — step-by-step

1. Client emails logistics@swishandclick.eu with order reference, defect description, photographs/video and Approved Control Sample reference, within the windows at clause 5.
2. Swish and Click OÜ acknowledges receipt and may request further evidence or a physical sample for supplier inspection.
3. If a return movement is required, Swish and Click OÜ issues a written RMA number specifying (a) the return address, (b) the carrier, (c) packaging requirements, (d) the deadline for collection/dispatch and (e) the documents required (commercial invoice for customs purposes, proforma, returns paperwork).
4. Client packages the Goods in their original packaging (or equivalent protection), marks the RMA number visibly on each carton, and either makes them available for collection or dispatches them in accordance with the RMA instructions.
5. The Goods are inspected on receipt (and, where applicable, sent on to the upstream supplier for further inspection).
6. Swish and Click OÜ confirms the outcome and processes the remedy in line with clause 6.

7.2 Return shipping costs

• Confirmed defects / non-conformities / damage in transit: Swish and Click OÜ or the supplier arranges and bears the cost of collection via the carrier nominated in the RMA. Returns booked by the Client without the nominated carrier may not be reimbursed.
• Non-defective returns (rare — only in agreed Goodwill or commercial-accommodation scenarios): the Client bears all return-shipping, customs, duties and insurance costs.

7.3 Customs and duties on return movements

For cross-border returns, the Client must use the customs procedures specified in the RMA (typically Returned Goods Relief / Outward Processing where applicable). Customs duties, import VAT, brokerage and customs-clearance fees on return movements are reimbursed by Swish and Click OÜ only where the return is for a confirmed defect and only to the extent agreed in the RMA. Duties triggered by incorrect customs declarations made by the Client (wrong tariff code, wrong value, wrong incoterm, wrong reason for return) are at the Client's cost.

7.4 Returns from outside the EU

Returns from non-EU jurisdictions (including but not limited to Switzerland, the United Kingdom, the United States and the United Arab Emirates) must use the customs procedures and incoterms set out in the RMA. The Client must ensure that the commercial invoice, packing list and returns paperwork accurately describe the Goods, value, country of origin and reason for return.

7.5 Returns into the EU from UK / CH

Returns from the United Kingdom or Switzerland into the EU require careful customs handling. Where Swish and Click OÜ arranges the return, the chosen carrier will handle Returned Goods Relief or equivalent. Where the Client arranges the return without complying with the RMA instructions, any avoidable import VAT, duties or carrier surcharges fall on the Client.

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8. Cancellations versus returns

Cancellations before delivery are governed by the Cancellation Fee Policy (Part 11 of the v2 ToS) and are outside the scope of this Policy. The Cancellation Fee Policy applies a graduated fee scale reflecting (i) supplier irrevocable commitments, (ii) decoration set-up costs already incurred, (iii) raw-material lock-in, (iv) production status, (v) restocking realities and (vi) freight commitments.

This Returns and Refunds Policy governs post-delivery scenarios: defective, damaged, non-conforming or short-delivered Goods; late delivery amounting to fundamental breach; and (where they apply) Consumer cooling-off and statutory conformity rights.

If you are uncertain which document applies, contact your account manager or info@swishandclick.eu and we will direct you to the correct process.

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9. Goodwill Resolution tier

Goodwill Resolution — codified, discretionary, without precedent

Above the strict-remedy process at clauses 5–7, Swish and Click OÜ operates a Goodwill Resolution tier. The Goodwill Resolution tier is expressly discretionary, granted case-by-case, without admission of liability, without prejudice to our legal position, and without precedent for future Orders or future complaints.

9.1 Discretionary, without precedent, without admission

A Goodwill Resolution is not an admission that the Goods are defective, that any Industry Tolerance has been exceeded, that any contractual term has been breached, or that any statutory right has been triggered. It is offered, where offered, as a commercial accommodation only. The fact that a Goodwill Resolution has been offered in respect of one Order does not create any right, expectation or course of dealing in respect of any other Order.

9.2 Criteria for goodwill

The factors Swish and Click OÜ may take into account in deciding whether to offer a Goodwill Resolution include (non-exhaustively):

• Account standing and order history of the Client;
• Order value and frequency, and the lifetime value of the relationship;
• Low-value / fast-resolution preference — small issues that are not worth either party's time to litigate procedurally;
• ESG considerations — including the carbon/landfill cost of return movements where the Goods can be put to a sensible secondary use;
• End-client relationship importance — where the Client's downstream relationship would suffer disproportionately;
• Genuine ambiguity in the defect, the Proof, the Approved Control Sample or the Industry Tolerance position;
• Speed of notification by the Client, and the quality of evidence provided;
• The Client's compliance with clauses 5.5–5.8 (RMA, evidence, no further use, original packaging).

9.3 Forms of goodwill

Forms a Goodwill Resolution may take include (non-exhaustively):

• partial credit note against the next Order;
• future-order discount of a specified percentage on a specified next Order;
• free reprint / re-supply of a small subset of the run;
• accelerated lead time on the next Order;
• free upgraded decoration or free upgraded packaging on the next Order;
• absorption of part of the customs / freight cost on the next Order;
• contribution to ESG-friendly disposal or donation of the affected Goods.

9.4 Acceptance is full and final settlement

Acceptance of a Goodwill Resolution is in full and final settlement of the complaint to which it relates. Once accepted in writing (including by email), the Client may not subsequently pursue the same complaint under the strict-remedy process at clauses 5–7, nor through the disputes process at clause 14, nor by way of chargeback under clause 10, nor otherwise.

9.5 The Client may insist on the strict-remedy process

The Client is never obliged to accept a Goodwill Resolution. The Client may always insist instead on the strict-remedy process at clauses 5–7, with the time-bars and evidential requirements that apply to it.

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10. Chargebacks and payment disputes

B2B chargeback restriction

B2B chargebacks for conforming Custom Goods are abusive. Swish and Click OÜ reserves the right to defend and recover the full amount of any such chargeback, together with all associated chargeback fees, evidence-preparation costs, legal fees, interest and the late-payment compensation set out in clause 10.3.

10.1 Complaint process must be exhausted first

Before any payment dispute, chargeback, card-scheme dispute or PayPal/Stripe/Klarna dispute is raised, the Client must:

1. raise the issue in writing with logistics@swishandclick.eu;
2. comply with the strict-remedy process at clauses 5–7 (including RMA and evidence);
3. allow Swish and Click OÜ a reasonable time to investigate and respond (clauses 5.9–5.10);
4. exhaust the disputes process at clause 14.

10.2 Card-scheme rules

For Custom Goods that have been delivered in accordance with the approved Proof and the Order Confirmation, a chargeback under the "merchandise not as described", "not received", "credit not processed" or equivalent reason codes is, in Swish and Click OÜ's view, contrary to the relevant card-scheme rules, including the Visa Core Rules and Visa Product and Service Rules and the Mastercard Chargeback Guide, which (i) require the cardholder to attempt resolution with the merchant first, (ii) recognise the legitimate B2B nature of bespoke and personalised goods, and (iii) permit the merchant to provide compelling evidence (Proof approval, Order Confirmation, delivery documentation, photographs of decoration) in defence of the transaction. Swish and Click OÜ will produce this compelling evidence in any chargeback representment.

10.3 Recovery of chargeback losses

Where a chargeback is determined in Swish and Click OÜ's favour, or where the underlying claim is one for which a chargeback would have been abusive, Swish and Click OÜ is entitled to recover the disputed amount, all chargeback fees, all bank/scheme fees, all evidence-preparation costs, statutory late-payment interest (ECB MRO + 8 percentage points; 10.15% from 1 January 2026 based on an ECB MRO of 2.15%) plus the €40 fixed sum per invoice under Directive 2011/7/EU on combating late payment in commercial transactions (or, for UK contracts, BoE base rate + 8% plus the £40/£70/£100 fixed-sum bands under the Late Payment of Commercial Debts (Interest) Act 1998, as amended), and reasonable recovery costs. Gowling WLGStevens & Bolton LLP

10.4 Consumer card-scheme rights are preserved

Nothing in this clause 10 limits the chargeback or card-scheme rights of a Consumer where those rights are mandatory under the Consumer's home-state law or the applicable card-scheme rules.

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11. Written cost breakdown obligation

On a reasoned written request from the Client challenging a particular fee, deduction, partial refund quantum, refusal or rejection under this Policy, Swish and Click OÜ will provide a written breakdown of how the fee, deduction or refusal was calculated within 10 Business Days.

The breakdown will identify, to the extent relevant: (i) the affected line items and quantities; (ii) the unit prices and totals; (iii) the proportion of the run affected; (iv) the materiality assessment for cosmetic-defect partial refunds; (v) the supplier-inspection conclusion (where shared); (vi) any deductions for further use, distribution, on-sale, decoration or modification after defect; (vii) the Industry Tolerance assessment; and (viii) the reasoning by reference to this Policy.

This obligation does not require Swish and Click OÜ to disclose commercially sensitive supplier pricing, supplier identity (where confidential), supplier markups, or internal margin calculations.

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12. Time bars and limitation

Statutory limitation periods of the applicable jurisdiction are preserved. Where mandatory law provides a longer notification or limitation window than this Policy, the mandatory law prevails.

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13. Mandatory consumer rights — final reservation

Mandatory consumer rights — final reservation

Nothing in this Policy limits, excludes or modifies any mandatory right that a Consumer has under the consumer-protection law of the Consumer's country of habitual residence, including (without limitation) the Spanish TRLGDCU as amended by Royal Decree-Law 7/2021, the French Code de la consommation including the AGEC Law and Article L. 217-13 6-month repair extension, the UK Consumer Rights Act 2015 (including the DMCC Act 2024 amendments in force from 6 April 2025), the Estonian Law of Obligations Act Chapter 11 and the Swiss Code of Obligations Articles 197–210. Where any provision of this Policy is, or would be, less favourable to a Consumer than a mandatory rule of the Consumer's home jurisdiction, that mandatory rule prevails to the extent of the conflict.

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14. Disputes and forum

14.1 First step — complaint process

All complaints must be addressed in the first instance to logistics@swishandclick.eu, with a copy to the Client's account manager. Swish and Click OÜ will acknowledge promptly and respond within the reasonable-time window at clause 5.10 (and, for Consumers, within the 15-day window required by Estonian consumer-protection law and equivalent home-state windows where mandatory).

14.2 B2B disputes — mediation and ECCI arbitration

For B2B disputes, and consistent with the v2 ToS:

• the parties shall attempt to resolve the dispute by good-faith mediation for 30 days from written notice of the dispute;
• failing mediation, the dispute shall be finally settled by arbitration under the Rules of the Arbitration Court of the Estonian Chamber of Commerce and Industry (ECCI) in force from 1 January 2024; International Bar Association
• the seat of arbitration is Tallinn, Estonia;
• the language of arbitration is English;
• the substantive law is the law of Estonia (without prejudice to mandatory Consumer-protection rules of the Consumer's home jurisdiction);
• disputes with a value up to and including €250,000 shall be decided by a sole arbitrator;
• disputes with a value up to and including €10,000 may, at the claimant's option, be brought before Harju Maakohus (Harju County Court) in Tallinn instead.

14.3 Consumer disputes — home-state forum preserved

For Consumer disputes, the Consumer's mandatory home-state forum and consumer-arbitration regime are preserved. The arbitration clause at clause 14.2 is not enforceable against a Consumer to the extent that it would deprive the Consumer of a mandatory home-state forum.

14.4 ODR platform

Consumers resident in the European Union may, where applicable, use the European Commission's Online Dispute Resolution platform: ec.europa.eu/consumers/odr. Our email address for ODR purposes is accounts@swishandclick.eu.

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15. Personal data

Personal data submitted in connection with a return or refund is processed in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR) and, where applicable, the Estonian Personal Data Protection Act and the UK GDPR / Data Protection Act 2018.

Personal data submitted under this Policy is used only for the purpose of processing the return, refund, credit, replacement or related complaint, including communications with the upstream supplier, carrier and payment-service provider where strictly necessary. Data is retained for the period required by Estonian accounting law (currently 7 years for accounting records) and by applicable mandatory law, and thereafter deleted. For full details of data subjects' rights, lawful bases, recipients, transfers and retention, please consult the Swish and Click OÜ Privacy Notice on the storefront.

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16. Language

This Policy is published in English, Spanish, Catalan, French and Italian. In the event of any conflict, ambiguity or inconsistency between the language versions, the English version prevails for the interpretation of the contractual relationship between Swish and Click OÜ and the Client, save where mandatory consumer-protection rules of the Consumer's home jurisdiction require otherwise (in which case the language version of the Consumer's home jurisdiction prevails to the extent of that mandatory rule).

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17. Changes to the Policy

Swish and Click OÜ may update this Policy from time to time. The version in force at the date of the Order Confirmation governs that Order, except where mandatory law (in particular mandatory Consumer-protection law) applies a different rule. The current and prior date-stamped versions are retained and available on request from info@swishandclick.eu. The version in force at the date of publication is v2 — Effective 12 May 2026.

Material amendments will be communicated to active account holders by email at least 30 days before they take effect, save for amendments required by mandatory law (which take effect on the date required by that law).

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18. Contact for returns

• Email: info@swishandclick.eu
• Phone: +39 353 202 5915
• Account manager: the named account manager allocated to the Client (or the general inbox where none is allocated)
• Notices of a formal or legal nature (e.g. service of legal proceedings, statutory notices) must be sent to the registered office at Lõõtsa tn 5, 11415 Tallinn, Estonia. Notices sent only to the Spanish virtual correspondence address at Gran Via de les Corts Catalanes 672, 08010 Barcelona, Spain, or to any other virtual / coworking / mail-handling address, are not validly served unless mandatory local law expressly so requires.

For ease of resolution, please include in any return/refund email: order number, Order Confirmation date, delivery date, affected SKU(s), quantity affected, defect description, photographs/video and Approved Control Sample reference.

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19. Company block

Swish and Click OÜ • Lõõtsa tn 5, 11415 Tallinn, Estonia • Estonian commercial register 17301303 • EU VAT EE102889941 • info@swishandclick.eu • +39 353 202 5915 • swishandclick.eu

All other addresses associated with Swish and Click OÜ — including Barcelona (Gran Via de les Corts Catalanes 672, 08010 Barcelona, Spain) and any other coworking, mail-handling or virtual-office addresses in Italy, Germany, Switzerland, the United Kingdom or elsewhere — are correspondence and mail-handling facilities only. Unless mandatory local law expressly determines otherwise, those addresses are not intended to constitute branches, registered offices, warehouses, operational offices, permanent establishments, places of effective management, tax establishments or addresses for service of legal proceedings. Swish & Click Ltd (United Kingdom) is the contracting party only where it is expressly named in a separate written contract, invoice or order confirmation; in the absence of such express naming, Swish and Click OÜ is the sole contracting party.

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End of Policy — v2 — Effective 12 May 2026