1. Identity and operation of the online store
The online store operates through the web address displayed on this website and provides visitors with the possibility to obtain information, select and purchase the products presented in its online catalogue, in accordance with these General Terms and Conditions and the applicable provisions of Greek and European law.
The Seller's legal company name, trade name, registered office, contact details, tax identification details and other information required by applicable law are set out on the “Legal Information and Seller Details” page, which serves as the reference point for identifying the actual entity carrying out the transactions.
The use of a particular trade name, distinctive title or web address does not, in itself, create a separate legal personality or alter the identity of the actual contracting Seller.
The Customer is able to obtain information about the business before submitting an order and to use the published means of communication for any matter concerning the transaction.
2. Actual contracting party and Seller liability
The Seller is the business that offers the products for sale, enters into the contract with the Customer and assumes the obligation to perform the specific transaction, as determined by the information provided before the order and by the relevant contractual and tax details.
Responsibility for performance of the contract, delivery of the agreed products, application of consumer rights and fulfilment of the obligations provided for by applicable law lies with the actual contracting Seller.
If third-party services are used to support the transaction, such as technical providers, transport companies, payment providers or external partners, their involvement does not automatically result in a transfer of the Seller's contractual obligations towards the Customer.
The allocation of responsibilities between the Seller and its third-party partners is governed by their actual contractual relationships and applicable law, without limiting rights that the Customer may lawfully exercise against the Seller.
3. Separation of commercial activity and technical management
The development, maintenance, hosting, technical support or management of the online store may be carried out by third-party providers or cooperating businesses acting within the scope of the services assigned to them.
Technical management of the website does not, by itself, mean that the relevant provider acquires the status of Seller or automatically assumes the commercial obligations arising from contracts for the purchase of products.
Likewise, the business making the sales is not released from its legal obligations towards Customers because particular technical or support functions have been assigned to third parties.
Each entity involved is responsible according to its actual role, the contractual obligations it has undertaken and the provisions applicable to its activities.
The information provided to the Customer must make it possible to identify the actual Seller and must not create confusion as to the identity of the business responsible for fulfilling the order.
4. Trade name, distinctive title and legal company name
The online store may use a trade name, distinctive title, logo or web address that differs from the legal company name of the entity carrying out the sales.
Use of these elements is intended for the commercial identification of the store and does not alter the legal identity of the business or, by itself, create a different contracting party.
Rights in trade names, distinctive signs, logos and other protected elements belong to their respective lawful right holders.
Any use of a third party's trademark for the purpose of identifying products does not automatically imply official representation, authorised distribution, commercial cooperation or any other contractual relationship with the trademark proprietor.
The Customer may consult the Seller's published details in order to establish the identity of the business with which the transaction is being concluded.
5. Shared technical infrastructure and network of online stores
The online store may use shared technical infrastructure, central information systems, hosting services, product-management software or other support functions that are also used by different online businesses.
The existence of shared technical services, similar design, common suppliers or comparable commercial catalogues does not, by itself, mean that all online stores form a single legal entity or that each business automatically assumes the obligations of the others.
The actual entity responsible for each transaction is determined by the legal identity of the business making the sale, the information provided to the Customer and the actual contractual relationships connected with the specific purchase.
Where several stores are operated by the same Seller, the relevant information must reflect the actual organisational and legal situation of the business.
These terms do not, by themselves, create an independent legal personality for each web address, nor can they exclude liability arising from mandatory statutory provisions or from the actual relationship between the parties involved.
6. Purpose and scope of the General Terms
These General Terms and Conditions govern access to and use of the online store, the presentation of products, the process for submitting and accepting orders, completion of payments, delivery of goods and the other contractual relationships arising from transactions between the Seller and the Customer.
The more specific information provided during the ordering process, the actual terms of the particular transaction and the mandatory-law provisions applicable in the relevant market are taken into account when determining the rights and obligations of the contracting parties.
Where specific terms apply to a particular product, service or commercial transaction, they must be communicated to the Customer before the corresponding contract is concluded.
These terms may not be interpreted as a general waiver of legal rights or as permitting unilateral alteration of material terms of the transaction that have already been agreed.
7. Consumer status and applicable protection
For the purposes of these terms, consumer status is determined in accordance with applicable law and the actual purpose for which the particular transaction is carried out.
A natural person purchasing products for purposes outside their trade, business, craft or professional activity may fall within the corresponding consumer-protection regime, provided that the legal conditions are met.
Consumer status is not automatically excluded because of the quantity of products ordered, the choice of a particular payment method or any other isolated feature of the transaction.
The Seller applies the mandatory provisions concerning distance sales, consumer information, delivery, withdrawal and conformity of goods to the extent that they apply to the particular transaction.
Any contractual provision that conflicts with a mandatory consumer right is treated in accordance with the consequences prescribed by applicable law.
8. Professional transactions and B2B sales
Transactions with businesses, professionals and other buyers acting within the scope of their commercial or professional activity may be governed by specific commercial terms, wholesale agreements, individually agreed prices and particular ordering and delivery procedures.
Such specific terms must be clearly defined and appropriately communicated to or agreed with the professional buyer before the corresponding contractual obligations are undertaken.
The buyer's actual professional status and the purpose of the particular transaction are taken into account when determining the applicable contractual regime.
Transactions between businesses may include particular agreements concerning quantities, delivery deadlines, method of payment, commercial credit, transport, customs clearance and the allocation of specific financial risks, insofar as these are permitted by applicable law.
Specific B2B agreements do not automatically alter the terms of other transactions and may not be used to exclude rights that are mandatorily granted to persons acting as consumers.
9. Information about and acceptance of the General Terms
The Customer is invited to read these General Terms and Conditions before finally submitting an order, so as to be informed of the material characteristics of the transaction, the procedures for its performance and the rights and obligations of the contracting parties.
The online store must provide an appropriate means of accessing the terms during the checkout process, without making the Customer's access to this information dependent on disproportionate technical or procedural obstacles.
Where express acceptance of the terms is required, the relevant procedure must enable the Customer to express acceptance clearly and must be linked to the version of the terms that was made available to the Customer.
The business may retain the necessary evidence concerning acceptance of the terms, the time at which the order was submitted and the information provided, in accordance with personal-data-protection requirements.
Acceptance of these terms does not constitute a waiver by the Customer of mandatory rights, nor does it render applicable a provision that is invalid or unfair under the law.
10. Applicable version of the terms and evidence
For each transaction, the contractual terms that were properly brought to the Customer's attention at the time the contract was concluded apply, together with any specific agreements concerning the particular order and the applicable mandatory statutory provisions.
The business must organise an appropriate system for recording versions of the terms so that it can identify the content that was available at the time a transaction took place.
Subsequent publication of amended terms does not automatically mean that the new terms apply retroactively to contracts already concluded.
In the event of a dispute concerning the content of the terms agreed, the available evidence relating to the transaction may be examined, including order information, relevant electronic confirmations and the corresponding stored version of the terms.
The retention and use of such data are carried out in accordance with the business's applicable obligations and personal-data-protection rules.
11. Change of supplier and preservation of the agreed product characteristics
The Seller may procure genuine products from different lawful suppliers provided that the particular commercial activity is permitted by applicable law and the obligations connected with making the relevant goods available are complied with.
A change of supplier does not automatically entail a change to the product agreed with the Customer.
The Seller must ensure that the goods delivered correspond to the agreed commercial identity, version, quantity and other material characteristics of the particular transaction.
Procurement of the same genuine product from a different lawful commercial source does not, by itself, create an obligation to change the agreed price or another material term.
If, by contrast, the change of supplier entails a change to the product itself or another agreed characteristic, the rules governing the particular modification of the contract apply.
Legal basis: Articles 5–7 of Directive (EU) 2019/771 concerning conformity of goods and Article 15 of Regulation (EU) 2017/1001 concerning exhaustion of trademark rights.
12. Human review of significant automated decisions
Where the business uses automated systems to assess transactions, prevent fraud, provide commercial credit or perform other functions that may significantly affect natural persons, it must examine the requirements applicable to the particular processing.
Where a particular decision is based solely on automated processing of personal data and produces legal effects or similarly significantly affects a person, the specific rules of Article 22 of the GDPR apply.
Where such a decision is permitted under a lawful exception, the business must implement the corresponding safeguards required by law.
Human review must constitute a genuine opportunity for substantive examination of the circumstances where required and not merely a formal confirmation of the initial automated decision.
Use of an algorithm does not provide a general right arbitrarily to exclude a Customer from a contract already concluded or restrict mandatory rights.
Legal basis: Articles 13–15 and 22 of Regulation (EU) 2016/679.
13. Delivery to a third person designated by the Customer
The Customer may designate another person as recipient of the goods where this is permitted by the particular contract and the available transport service.
The relevant choice must be specified with sufficient clarity so that the Seller and carrier can identify the agreed recipient and intended place of delivery.
Where the goods are delivered to a third person designated by the consumer and that person is not the carrier, transfer of risk is assessed in accordance with Article 20 of Directive 2011/83/EU.
The mere presence of a third person at the delivery address does not automatically prove that the person had been designated by the Customer as the lawful recipient.
If receipt is disputed, the Seller examines the information provided when the order was placed, the available proof of delivery and the actual circumstances.
The Seller may not generally exclude liability by relying on the fact that the parcel was handed to any person found at the stated address where the conditions for lawful performance of the contractual obligation are not met.
The business retains the ability to request from the carrier additional lawfully available information to verify actual delivery.
Legal basis: Article 20 of Directive 2011/83/EU concerning physical possession of the goods by the consumer or a third person designated by the consumer.
14. Delivery to a collection point, automated locker or other agreed facility
The Seller may offer delivery services to a carrier's branch, collection point, automated locker or another facility supported by the selected transport service.
The Customer is informed of the material conditions for using the particular service, including the collection method, available holding period and actual procedures applied by the carrier.
Arrival of the parcel at a collection point does not automatically mean, in every case, that the consumer has acquired physical possession of the goods or that risk has been lawfully transferred.
Delivery is assessed in accordance with the particular contract, the nature of the selected service, the actual circumstances and the applicable provisions.
If the Customer does not collect the parcel within the available holding period, the Seller examines the actual reason for non-collection and the consequences provided by the lawful agreement.
Failure to collect from a delivery point does not automatically constitute exercise of the right of withdrawal and does not provide a general right to retain the entire price paid.
The business may communicate with the Customer to resolve the outstanding matter and consider the available lawful options for delivery or return of the shipment.
Legal basis: Articles 18 and 20 of Directive 2011/83/EU together with the lawful terms of the particular transport service.
15. Issuance of tax documents, identification of the actual Seller and tax documentation
The Seller must issue the tax documents required by applicable law for actual sales of goods and other taxable transactions carried out through the online store.
The appropriate document is issued by the actual entity responsible for the transaction in accordance with the legal identity of the business, the applicable tax regime and the details of the particular sale.
Use of a different trade name, web address, central information system or external technical provider does not automatically alter the identity of the person bearing the legal tax obligation.
The relevant documents must reflect the actual details of the transaction, including the date, subject matter of the sale, quantities, value and other information required for the particular type of document.
Where the business uses automated systems for issuing, transmitting or storing tax documents, the corresponding process must be organised in accordance with the obligations applicable to the actual taxable entity.
In the event of cancellation, refund or change in the value of a particular transaction, the Seller examines issuance of the corresponding corrective or credit documents in accordance with the applicable tax rules.
An electronic order confirmation or transaction receipt from the payment provider does not automatically replace the tax document required for the particular sale.
The business must retain tax records in accordance with the applicable obligations and take appropriate measures to protect information containing personal data of natural persons.
Legal basis: Articles 220–226 and 242–244 of Directive 2006/112/EC concerning issuance, content and retention of invoices and accounting records. Greek tax obligations additionally require application of the national tax framework in force and the rules on electronic transmission of documents where applicable.
16. Lawfulness of making products available on the Greek market
The Seller must examine the lawfulness of making each category of products available on the Greek market, taking into account the rules concerning marketing, safety, labelling, tax treatment and any specific sales restrictions.
The lawful operation of the online store as a business does not automatically mean that every product that can be entered in the commercial catalogue may be offered online without additional conditions.
For products subject to a specific regulatory regime, the business examines the requirements applicable to the particular transaction and to its actual role as seller, distributor, importer or other economic operator.
The existence of a lawful supplier or possession of a purchase tax document does not, by itself, constitute complete proof that every form of subsequent commercial distribution is permitted.
Where doubt arises as to whether a particular item may lawfully be sold, the Seller examines the actual classification of the product, the applicable provisions and the relevant obligations before continuing to make it available.
This provision does not constitute a general statement that all products in the online catalogue may be sold to every consumer or shipped to any destination.
Legal basis: Greek Law 2251/1994 on consumer protection, Greek Law 4419/2016 adapting Greek legislation to Directive 2014/40/EU to the extent it concerns covered products, and Regulation (EU) 2023/988 on general product safety for products falling within its scope.
17. Obligation to return goods following lawful withdrawal
Where the consumer lawfully exercises the right of withdrawal from a contract for the sale of goods, the consumer must return the goods to the Seller or to a person authorised by the Seller to receive them in accordance with the applicable provisions.
Unless the Seller has offered to collect the goods itself, the consumer must return them without undue delay and, as a rule, within fourteen days from the day on which the decision to withdraw was communicated.
The relevant period is met where the consumer sends the goods before it expires.
The Seller may provide appropriate information concerning the return address, identification of the order and other practical details facilitating the process.
The business may not impose disproportionate procedural conditions that make exercise of the right of withdrawal unjustifiably difficult.
Return of goods following ordinary withdrawal must be distinguished from return of a product due to lack of conformity or another defective performance of the contract.
In each case, the specific rules corresponding to the actual reason for the return apply.
Legal basis: Article 14(1) of Directive 2011/83/EU.
18. Judicial protection, applicable law and jurisdiction in cross-border transactions
The Seller and the Customer retain the rights to judicial protection granted to them by applicable law in the event of a dispute concerning interpretation, performance or termination of the particular contract.
Any choice of a particular applicable law is made in accordance with the rules of private international law applicable to the relevant transaction.
Where the contract is concluded with a consumer and the conditions of Article 6 of the Rome I Regulation are met, a choice of applicable law may not deprive the consumer of the protection of the mandatory provisions of the law that would have applied in the absence of that choice.
The existence of a different language version of the website or a foreign web address does not, by itself, determine the applicable law or the jurisdiction of the courts.
The Seller may not impose a general exclusive-jurisdiction clause in a manner that breaches mandatory consumer-protection provisions.
The business retains the ability to pursue lawful claims for actual contractual breach or proven loss in accordance with the procedures provided by applicable law.
Legal basis: Articles 3 and 6 of Regulation (EC) No 593/2008 (Rome I) and Articles 17–19 of Regulation (EU) No 1215/2012 concerning jurisdiction in consumer contracts.
19. Geographic restrictions, cross-border access and objective conditions of supply
The Seller may organise the geographical scope of its commercial activity and the areas in which it provides delivery services in accordance with its actual operational capabilities and applicable law.
Restrictions concerning particular countries or product categories must be based on genuine and lawful reasons, such as specific prohibitions on making products available, import restrictions, safety requirements, availability of transport services or other objective circumstances.
The business may not assume that the existence of a different language version or the Customer's residence in another country gives it a general right to apply any restriction irrespective of the requirements of Union law.
Likewise, legislation on unjustified geo-blocking does not create a general obligation to provide delivery services in every country of the European Union irrespective of the Seller's actual commercial terms.
If the Seller applies different service areas or delivery conditions, the relevant information must be presented clearly and must correspond to the lawful possibilities for performing the transaction.
The existence of a lawful geographical restriction does not release the business from obligations arising from a particular contract that has already been concluded.
Legal basis: Regulation (EU) 2018/302 on addressing unjustified geo-blocking, in particular Articles 3 and 4, subject to the exceptions and specific provisions applicable to the relevant product categories.
20. Access security and protection of information systems
Access to the store's electronic services must take place in accordance with the lawful use for which those services are provided.
Unauthorised access to third-party accounts, unlawful acquisition of data, introduction of malicious software, alteration of information or any other act that compromises the security of information systems is prohibited.
The Seller may apply appropriate technical and organisational protective measures, such as authentication mechanisms, access controls, restrictions on malicious automated activity and security-incident response procedures.
Such measures must be appropriate to the intended purpose and applied in accordance with the relevant legislation, including personal-data-protection requirements.
The use of security mechanisms does not give the Seller an unlimited right to access the content of private communications or collect information that is not necessary for a lawful and specific purpose.
In the event of an identified security incident, the business takes the necessary response measures and fulfils any information or notification obligations imposed by applicable law.
Legal basis: Article 5(1)(b) and (c), Articles 6 and 32 of Regulation (EU) 2016/679 concerning purpose limitation, data minimisation, lawfulness of processing and security of personal data.
21. Obligation to deliver goods that conform to the contract
The Seller is required to deliver goods that meet the subjective and objective conformity requirements laid down by applicable law.
Conformity is assessed on the basis of the description, type, quantity, quality, functionality, compatibility and other characteristics agreed in the context of the particular transaction.
The goods must also be fit for the ordinary purposes for which goods of the same type are used to the extent required by the objective conformity conditions.
The Seller must take into account public statements concerning particular characteristics of the product in accordance with the specific conditions laid down by law.
Use of information supplied by the manufacturer or supplier does not automatically release the Seller from its obligations towards the consumer.
Delivery of a different product or a different quantity from that agreed is assessed under the conformity rules even where the business regards the goods delivered as commercially equivalent.
Legal basis: Articles 5, 6, 7 and 8 of Directive (EU) 2019/771.
22. Statutory liability of the Seller and temporal protection of the consumer
The Seller is liable to the consumer for lack of conformity of the goods in accordance with the temporal and substantive conditions laid down by the applicable legislation.
Directive (EU) 2019/771 provides for the Seller's liability for lack of conformity that exists at the time of delivery and becomes apparent within the prescribed period, without prejudice to specific or more favourable national provisions.
The rules concerning the burden of proof apply in accordance with the specific provisions and the national law governing the particular transaction.
The Seller may not assume that the existence of a short manufacturer's commercial guarantee automatically restricts the duration or scope of the Seller's statutory liability.
Where a particular product shows a lack of conformity, the business examines the Customer's claim on the basis of the actual time of delivery, the nature of the goods, the available evidence and the applicable provisions.
The business retains any statutory rights it may have against the supplier or another previous party in the commercial chain, without exercise of those rights constituting a general prerequisite for satisfying the consumer's claim.
Legal basis: Articles 10, 11 and 18 of Directive (EU) 2019/771.
23. Lawfulness of sales to other countries of the European Union and to third countries
The possibility of selling and shipping products online to countries other than the Seller's country of establishment depends on the nature of the particular goods, the terms of the transaction and the provisions applicable in the country of destination.
The business may operate a multilingual website and provide visitors from different countries with access to its commercial catalogue, without this automatically meaning that every product is available for shipment to all destinations.
Before enabling shipment of a particular category of products to another country, the Seller examines the applicable rules governing marketing, importation, labelling, taxation and safety.
Shipments outside the European Union may require additional customs, tax or other administrative procedures, which must be taken into account before a binding delivery obligation is undertaken.
Acceptance of an order does not entitle the Seller to circumvent import or marketing prohibitions applicable at the destination of the particular shipment.
Where performance of a particular order is not legally possible, the consequences for the contract and any amounts already paid are dealt with in accordance with the applicable law and the actual circumstances.
Legal basis: Article 18 of Directive 2014/40/EU concerning cross-border sales of the products covered by it, Article 4 of Regulation (EU) 2023/988 concerning distance offers of products on the Union market, and Article 18 of Directive 2011/83/EU concerning the contractual obligation to deliver.
24. Delivery on a specific date and particular importance of the agreed deadline
Where, before conclusion of the contract, the Customer informs the Seller that the goods must be delivered by a specific date and that condition constitutes an essential element of the transaction, the importance of the deadline is taken into account when determining the contractual obligations.
The particular importance of the date may arise from the nature of the goods, the actual purpose of the order or specific circumstances communicated to the Seller before the purchase.
Where the delivery date constitutes an essential term of the contract, failure to deliver on time is dealt with in accordance with the specific provisions of applicable law.
The Seller may not assume that merely referring to indicative transit times automatically excludes the legal consequences of failing to meet an agreed essential deadline.
If the Customer has stated that delivery by a particular date is essential and the Seller does not deliver the goods on time, the conditions for immediate termination of the contract without first granting an additional period may be met.
In the event of lawful termination, the corresponding refund obligations apply, without prejudice to other rights provided by applicable national law.
Legal basis: Article 18(2)–(4) of Directive 2011/83/EU.
25. Licence to use photographs and advertising material of manufacturers and suppliers
The Seller may use photographs, commercial descriptions, technical information and other material of manufacturers or suppliers where the necessary rights of use are held or another lawful basis exists for the particular use.
Lawful purchase and resale of a product does not automatically confer an unlimited right to reproduce every photograph, advertising file or other protected work created by the manufacturer or a third party.
Where material is supplied under a licence, the business must take into account the duration, purpose, permitted publication channels and other terms of the particular grant.
Permission to use a photograph in one online store does not automatically amount to permission to use it on an unlimited number of different domains or in independent advertising services.
The Seller may maintain a record of the relevant licences and information proving the origin and permitted scope of use of the material.
Legal basis: Articles 2 and 3 of Directive 2001/29/EC concerning the rights of reproduction and communication of works to the public to the extent that the material is protected by copyright.
26. Prevention of fraudulent transactions, unauthorised use of payment instruments and protection of personal data
The Seller may apply appropriate technical and organisational measures to prevent, identify and investigate incidents that may be connected with unauthorised payment transactions, unlawful access to accounts or other genuine indications of fraud.
Such measures may include the use of secure payment services, appropriate authentication mechanisms, checks for unusual transactional activity and other procedures proportionate to the actual risk of the particular transaction.
Fraud-prevention measures must be applied in accordance with the principle of proportionality, applicable personal-data-protection obligations and the rights of persons affected by the relevant processing.
The existence of an unusual order, a different country of origin of the payment, a large quantity of products or another isolated characteristic does not automatically constitute proof of fraudulent conduct.
Where a particular transaction presents documented indications of risk, the Seller may assess the need for additional lawful confirmation or cooperation with the competent payment-service provider in accordance with the applicable contractual and legal obligations.
The business must not ask the Customer to disclose personal passwords, secret authentication codes or other security data that are not necessary for lawful performance of the transaction.
Where automated systems are used to assess transactional risk, the Seller examines the transparency and personal-data-protection requirements applicable to the particular processing.
Where a decision is based solely on automated processing and produces legal effects concerning a natural person or similarly significantly affects that person, application of the specific restrictions and safeguards laid down by the GDPR must also be considered.
The Seller may not use a general contractual anti-fraud clause to arbitrarily exclude consumer rights or retain personal data indefinitely without an appropriate lawful basis.
Legal basis: Articles 5, 6, 22 and 32 of Regulation (EU) 2016/679 concerning lawful processing, automated decisions and security of personal data. Article 97 of Directive (EU) 2015/2366 concerning strong customer authentication.
27. Customer request to change an order after submission
The Customer may request modification of a particular order after it has been submitted by using the available means of communication of the online store.
The request may concern, by way of example, a change in quantity, selection of a different product version, correction of delivery details, addition or removal of goods or a change to an available transport service.
The possibility of making the change is assessed according to the stage of order processing, actual product availability, payment status and the capabilities of the selected shipping service.
Where the contract has already been concluded, a request for modification does not automatically mean that the Seller is required to accept any change to the agreed subject matter, except where such an obligation is provided by law or the particular agreement.
If the modification is accepted, the parties must be able to identify the newly agreed characteristics, final price, any additional or reduced charges and the consequences for the delivery time.
If the order has already been dispatched, the possibility of changing the address or delivery details may depend on the actual capabilities of the transport service and the corresponding legal obligations.
An inability to make an optional change does not restrict the right of withdrawal or other consumer rights that apply independently of the possibility of modifying the original order.
Legal basis: Articles 6 and 8 of Directive 2011/83/EU concerning disclosed transaction terms and Articles 9–16 of the same Directive concerning the right of withdrawal where applicable.
28. Unsuccessful delivery attempt and rescheduling procedure
Where the first delivery attempt is unsuccessful, the Seller may cooperate with the carrier to investigate the actual cause of the incident and consider the available options for completing the shipment.
An unsuccessful delivery may be connected with the temporary absence of the recipient, incomplete address details, an objective inability to access the place of delivery or another factual circumstance.
The business may inform the Customer of the failed attempt and the available rescheduling or collection procedures.
The existence of an unsuccessful delivery attempt does not automatically mean that the Customer is responsible for every subsequent delay or that the Seller is released from its contractual obligations.
If the incident was caused by inaccurate information provided by the Customer, the relevant consequences are assessed according to the actual cause and the lawfully agreed terms.
If the unsuccessful delivery is connected with an error by the Seller or by a carrier offered by the Seller, the business must address the problem in accordance with its applicable obligations.
A new delivery attempt and any additional charge must be based on a lawful contractual basis and must not be used as an arbitrary financial burden on the Customer.
Legal basis: Articles 6, 18 and 20 of Directive 2011/83/EU.
29. Cancellation or termination of an order after conclusion of a binding contract
After conclusion of a binding sales contract, cancellation or termination of the transaction takes place in accordance with contractual terms that lawfully apply, the actual circumstances and the mandatory provisions governing the rights of the parties.
The Seller does not have a general and unlimited right unilaterally to cancel a contract already concluded solely because of a subsequent change in commercial price, procurement cost or another ordinary business parameter.
An inability to perform the transaction is assessed on the basis of its actual cause, the applicable provisions and the obligations undertaken by the parties.
The consumer retains the right of withdrawal provided for the relevant distance contracts, subject to the specific statutory exceptions.
Likewise, where the Seller fails to fulfil the agreed delivery obligation, the Customer may have the specific rights provided by law, including the possibility of terminating the contract where the relevant conditions are met.
If the contract is lawfully terminated, the business must deal with amounts paid and other consequences in accordance with applicable law and the reason for termination.
The existence of a separate commercial cancellation procedure does not extinguish or restrict rights mandatorily provided to the consumer.
Legal basis: Articles 9–16 and 18 of Directive 2011/83/EU concerning withdrawal and failure to deliver on time; Articles 13 and 16 of Directive (EU) 2019/771 concerning termination of the contract due to lack of conformity of goods.
30. Product authenticity, lawful procurement and protection against counterfeit goods
The Seller ensures that products made available through the online store come from lawful commercial sources and are not presented as genuine products of a particular manufacturer where they do not correspond to the relevant commercial identity.
Products may be procured from manufacturers, importers, wholesalers, distributors or other lawful suppliers, provided that the particular commercial activity is permitted by applicable law and does not infringe third-party rights.
The business may retain the necessary commercial and tax procurement documents, supplier information and other records required to document the origin and lawful distribution of the goods.
The making available of genuine products placed on the market in the European Economic Area by the trademark proprietor or with the proprietor's consent is assessed in accordance with the rules on exhaustion of trademark rights, subject to cases in which the proprietor has legitimate reasons to oppose further commercialisation.
The fact that a product is genuine does not release the Seller from compliance with specific sales, import, safety or tax restrictions applicable to the particular category of goods and destination country.
If a credible indication arises that a particular product is counterfeit, has disputed origin or does not satisfy the requirements for lawful making available, the business examines the factual circumstances and takes the measures required by law.
Legal basis: Articles 9, 14 and 15 of Regulation (EU) 2017/1001 concerning rights in European Union trademarks, limitations on their effects and exhaustion of trademark rights.
31. Loss of a parcel in transit and the Customer's rights
Where a particular shipment cannot be located or there are reliable indications that the parcel has been lost in transit, the Seller must examine the incident and its contractual obligations towards the Customer.
The business may ask the carrier to conduct an investigation in order to locate the shipment and determine the actual cause of the loss.
The investigation process does not automatically suspend the mandatory rights available to the consumer as a result of non-delivery of the goods.
Where the carrier was selected from among the services offered by the Seller, transfer of the risk of loss is assessed in accordance with Article 20 of Directive 2011/83/EU.
Where it is established that the goods were not delivered and the Seller remains under an obligation to deliver them, the relevant rules on performance of the contract and the Customer's rights arising from non-delivery apply.
The business may propose a new shipment of the agreed products, provided that the relevant process complies with its statutory and contractual obligations.
Where the conditions for lawful termination of the contract due to non-delivery are met, the Seller must reimburse the corresponding amounts due without undue delay.
The Seller's ability to claim compensation from the carrier is a separate matter and does not automatically extinguish the Customer's rights under the sales contract.
Legal basis: Article 18(2)–(4) and Article 20 of Directive 2011/83/EU.
32. Actual characteristics and description of products
Products made available through the online store are presented with descriptions intended to provide the material information the Customer needs in order to identify the product and make an informed purchasing decision.
The description of each product must correspond to the actual characteristics of the particular item, including, where required, the trade name, manufacturer, type, size, quantity, packaging, materials and other characteristics that materially affect the buyer's choice.
The Seller may use information from manufacturers and suppliers, without the origin of that information automatically releasing the Seller from its obligations towards the consumer concerning correct presentation and conformity of the product delivered.
If a particular description is found to contain inaccurate or incomplete material information, the business must make the necessary corrections and deal with the consequences for affected transactions in accordance with the law.
The ability to correct the future presentation of a product does not give the Seller the right unilaterally to alter characteristics already agreed in a completed contract.
Legal basis: Article 6(1)(a) of Directive 2011/83/EU; Articles 5, 6 and 7 of Directive (EU) 2019/771 concerning conformity of goods; Article 6 of Directive 2005/29/EC concerning misleading commercial practices.
33. Protection of the lawful resale of genuine products and exhaustion of trademark rights
The Seller may make available genuine products of third-party manufacturers in accordance with the provisions governing the lawful marketing of goods and the protection of the corresponding intellectual-property rights.
Where specific goods have been placed on the market in the European Economic Area by the proprietor of the trademark or with the proprietor's consent, the rules on exhaustion of rights laid down in Article 15 of Regulation (EU) 2017/1001 apply.
Exhaustion does not mean that the right holder is in every case deprived of the possibility of opposing further commercialisation. The Regulation recognises specific circumstances in which legitimate reasons for opposition may exist, in particular where the condition of the goods has been changed or impaired after they were first placed on the market.
The Seller may retain appropriate commercial records documenting the lawful procurement and distribution of its products.
The absence of a direct contractual relationship with a particular manufacturer does not automatically mean that every resale of that manufacturer's genuine product is prohibited.
Likewise, the fact that a product is genuine does not release the Seller from compliance with specific restrictions concerning sale, safety or importation.
Legal basis: Articles 9, 14 and 15 of Regulation (EU) 2017/1001.
34. Transaction currency, exchange-rate differences and transparency of the actual amount payable
Prices of products made available through the online store are presented in the currency applicable to the particular commercial transaction, in accordance with the information provided to the Customer before final submission of the order.
Where the store supports more than one currency or provides indicative currency conversion for the convenience of visitors from other countries, the presentation must enable a distinction to be made between indicative information and the actual billing currency.
The Customer must be able to identify the currency and amount in which the contractual payment obligation is undertaken, without creating a misleading impression concerning the final financial burden.
Where payment is made through a bank account or card using a different currency, the relevant provider may apply currency conversion in accordance with the lawful and contractual terms of its service.
The Seller is not automatically liable for every independent exchange-rate difference or charge imposed by a third-party provider. This provision does not limit the Seller's obligations concerning correct presentation of the agreed price and avoidance of incorrect charges by its own systems.
If the transaction is lawfully cancelled or an obligation to refund arises, the business must make the refund in accordance with the specific provisions applicable to the actual reason for reimbursement.
Exchange-rate differences that may arise from independent third-party services are assessed separately from the Seller's obligation to refund the amount due under the particular contract and applicable law.
The Seller may not use a general exchange-rate-differences clause to arbitrarily retain amounts due to the Customer or alter the agreed price of a contract already concluded.
Legal basis: Article 6(1)(e) of Directive 2011/83/EU concerning information on the total price; Article 59 of Directive (EU) 2015/2366 concerning currency conversion; Article 13 of Directive 2011/83/EU concerning the means and execution of reimbursement in the event of withdrawal.
35. Receipt, recording and management of Customer complaints
The Seller organises an appropriate process for receiving and examining complaints relating to transactions through the online store.
Complaints may concern the ordering process, payment, availability of goods, delivery, conformity of products, reimbursement or another matter connected with the particular contract.
The Customer may use the store's published communication channels to report the problem and request its examination.
The Seller may record the order number, the date of communication, the nature of the complaint and other information necessary for effective investigation.
The existence of an internal complaint-management system does not permit the imposition of additional conditions restricting mandatory consumer rights.
The business must examine each complaint on the basis of the actual circumstances and avoid automatically rejecting it solely because an optional commercial period has expired.
Legal basis: Articles 13–16 and 21 of Directive (EU) 2019/771 where the complaint concerns a lack of conformity. Articles 9–16 and 18 of Directive 2011/83/EU where it concerns withdrawal or non-delivery.
36. Specific restrictions on electronic commerce and distinction from sales through physical stores
The possibility of lawfully selling a product in a physical store does not automatically mean that it may be supplied on the same terms through the internet, telephone ordering or another form of distance transaction.
The Seller must examine whether the applicable legislation imposes specific obligations or restrictions connected with the method of sale, ordering process, identification of the buyer or place of delivery.
Specific requirements may differ between retail and professional transactions, domestic and cross-border sales, or products belonging to different regulatory categories.
The business may not use a different trade name or different technical infrastructure as a substitute for actual compliance with the requirements governing the particular transaction.
Where a specific provision permits a product to be supplied only through a particular sales channel, the corresponding commercial activity must be limited to the permitted forms of supply.
This provision does not create a general prohibition on electronic commerce for every product commercially associated with a particular regulated category. Application of specific restrictions requires correct classification of the actual product and examination of the corresponding legislation.
Legal basis: Directive 2014/40/EU, in particular Article 18, and the specific national provisions governing electronic supply of products falling within their scope.
37. Individual packs and the actual unit of sale
The unit of sale of each product must be specified in a manner that allows the Customer to know the actual quantity of goods included in the agreed price.
Where the price relates to a single booklet, packet of filters, pack of paper tips or another particular product, the commercial presentation must avoid creating the misleading impression that the price relates to a larger quantity.
If a product is available both individually and in a multipack, the respective options must be appropriately distinguished so as to reduce the risk of an incorrect order.
The use of photographs showing multiple units of a product must not create an inaccurate impression as to the actual quantity being purchased where the photograph may influence the Customer's decision.
Where the presentation of the unit of sale does not correspond to the quantity agreed, the statutory consequences of the particular lack of conformity apply.
Legal basis: Article 6(1)(a) of Directive 2011/83/EU, Article 6 of Directive (EU) 2019/771 and Article 6(1) of Directive 2005/29/EC concerning the essential characteristics and quantity of products.
38. Provision of safety warnings in the language of the market where the product is made available
Required warnings and safety information must be provided in accordance with the language requirements applicable in the country in which the particular product is made available.
Where Article 19 of Regulation (EU) 2023/988 applies, the online offer must contain the required safety information in a language that can be easily understood by consumers, as determined by the relevant Member State.
The business must distinguish a general commercial translation of a description from the accurate rendering of a mandatory warning or safety instruction.
Use of an automated translation tool does not release the Seller from the obligations applicable to the particular making available of the product.
Where a particular warning contains technical or specialised information, the Seller ensures that the translation does not alter its substantive meaning.
The existence of a Greek, English or other language version of the website does not automatically mean that all safety requirements of every destination country are satisfied.
Legal basis: Article 19(d) and Article 21 of Regulation (EU) 2023/988 to the extent applicable to the particular product category.
39. Central register of restrictions by country, product and form of commercial activity
The business may maintain a central register of restrictions affecting the sale, advertising, importation, shipment or commercial presentation of the products it makes available.
For each product or category of goods, the actual commercial and regulatory classification, the countries in which the possibility of making it available is being assessed, the corresponding legal sources and the available information concerning the application of specific restrictions may be recorded.
The business must distinguish restrictions relating to the nature of the product from those connected solely with a particular sales channel, a particular country or an advertising service.
The existence of a ban on advertising a particular product does not automatically amount to a general prohibition of every lawful activity associated with that product where the relevant legislation provides for a different scope.
Likewise, the absence of a specific prohibition in one country does not automatically create a right to make the product available online to any destination.
The register must be updated when the actual characteristics of a product, the applicable law or the terms of the particular commercial activity change.
The existence of the register is an organisational documentation measure and does not replace actual compliance with the applicable mandatory provisions.
Legal basis: Articles 5, 9, 11, 12 and 19 of Regulation (EU) 2023/988 to the extent applicable, together with the specific national and Union provisions governing the particular product category.
40. Special tax charges and different tax treatment of products
The tax treatment of each transaction is determined according to the actual type of product, the status of the contracting parties, the place of delivery and the applicable provisions governing the corresponding commercial activity.
The business must distinguish ordinary Value Added Tax charges from any excise duties, customs duties or other special tax obligations that may apply to particular categories of goods.
The inclusion of different products in the same online catalogue does not mean that they are automatically subject to the same tax treatment.
For cross-border transactions, the tax obligations applicable in the particular country and to the relevant type of sale must be examined separately, including the rules concerning distance transactions and imports.
The Seller must disclose to the Customer the information concerning price and additional charges required before conclusion of the contract and may not rely on a general clause to impose undisclosed charges afterwards in breach of the law.
The appropriate tax document is issued and the corresponding tax obligations are fulfilled by the competent entity involved in the actual transaction, in accordance with the applicable regime.
Legal basis: Directive 2006/112/EC on the common system of VAT, Directive (EU) 2020/262 on the general arrangements for excise duty to the extent applicable to the relevant product, and Article 6(1)(e) of Directive 2011/83/EU.
41. Replacement of non-conforming products and delivery of suitable goods
Where the product delivered lacks conformity, the consumer may be entitled to replacement with goods that conform to the particular contract, subject to the legal conditions.
Replacement is carried out with a product having the agreed characteristics, corresponding quantity and required quality.
The Seller may not assume that any goods of the same brand or commercial category automatically constitute a suitable substitute for the product agreed.
Replacement must be carried out free of charge, within a reasonable period and without significant inconvenience to the consumer.
The Seller bears the cost of taking back the goods being replaced, in accordance with the specific requirements of the law.
If replacement is impossible or would entail disproportionate cost compared with another lawful remedy, the relevant provisions determining the rights of the parties apply.
The business may not impose an additional charge solely for fulfilling a legal obligation to replace non-conforming goods.
Legal basis: Article 13(2)–(4) and Article 14 of Directive (EU) 2019/771.
42. Lack of stock after an order has been submitted and lawful treatment of inability to perform
Where, after submission of a particular order, it is established that one or more ordered products are unavailable in the quantity or version selected, the Seller examines the actual cause of the shortage and the stage reached by the corresponding transaction.
Lack of stock may result from simultaneous orders, delayed updating of available quantities, inaccurate information from an external supplier, a technical product-matching error or another actual change in availability.
The Seller must inform the Customer without undue delay where lack of stock materially affects the ability to perform the order in accordance with the agreed terms.
Where the contract has already been concluded, lack of stock does not automatically release the Seller from its obligations. The business examines the possibility of performing the contract, the applicable time limits and the Customer's rights under the relevant provisions.
The Seller may propose later delivery, a different version or an alternative product to the Customer, provided that the proposal is lawful and clearly presented. Such a proposal does not automatically amend the original contract without the required agreement.
If the agreed delivery is not made within the prescribed period, the corresponding statutory consequences apply. Where the conditions for termination of the contract are met, the Seller reimburses the amounts due in accordance with the applicable requirements.
The business may not unilaterally impose on the Customer a different product, a higher price or a later delivery date solely because its supplier is unable to provide the quantity originally agreed.
Legal basis: Article 18(1)–(4) of Directive 2011/83/EU concerning delivery, the additional period, termination of the contract and reimbursement of amounts paid.
43. Evidence, photographic documentation and lawful investigation of complaints
The Seller may ask the Customer for information that is necessary and appropriate for investigating a particular complaint, taking into account the nature of the product and the actual substance of the reported issue.
Such information may include the order number, a description of the problem, photographs of the delivered product or other information facilitating determination of the facts.
Collection of evidential material must be proportionate and limited to information necessary for the particular lawful purpose.
The Seller may not require disproportionate or objectively impossible documentation as a general condition for examining a lawful claim.
The absence of a photograph does not automatically mean that the complaint is unfounded where the actual lack of conformity can be established by another appropriate means.
Where the incident requires physical inspection of the goods, the procedure must be organised in accordance with the applicable rules and without passing on to the consumer costs that legally fall on the Seller.
Legal basis: Articles 11, 13 and 14 of Directive (EU) 2019/771; Articles 5 and 6 of the GDPR where the documentation includes personal data.
44. Updating order status and obligation to provide accurate information to the Customer
The Seller may provide an electronic order-tracking service through which the Customer is informed of the stage of registration, processing, payment, preparation, shipment or delivery of the products ordered.
Status information may originate from the store's information system, the relevant payment services, the carrier or other lawful sources used to perform the particular transaction.
The Seller takes steps to ensure that the information presented to the Customer corresponds, as far as possible, to the actual status of the order and does not create a misleading impression concerning completion of payment or delivery.
A technical indication that an order has been shipped does not automatically constitute proof that the goods have been delivered to the Customer or that lawful transfer of the risk of loss or damage has occurred.
Likewise, display of a status such as “completed” in the information system does not automatically extinguish the Customer's contractual rights where actual delivery has not taken place or where the delivered goods show a lack of conformity.
Where a material error in order-status information is identified, the business examines the available data and provides the Customer with the necessary clarification concerning the actual progress of the transaction.
The tracking service does not replace the Seller's statutory obligations concerning timely delivery and provision of information required during performance of the contract.
Legal basis: Articles 18 and 20 of Directive 2011/83/EU concerning the delivery obligation and transfer of risk; Articles 6 and 7 of Directive 2005/29/EC concerning avoidance of misleading commercial information.
45. Cancellation of an order before conclusion of a binding contract
The possibility of cancelling an order before conclusion of a binding contract is assessed in accordance with the actual submission and acceptance process used by the online store.
Where submission of an order constitutes an offer by the Customer to the Seller and the contract has not yet been concluded, the consequences of any withdrawal of the offer or non-acceptance of the order are determined by the applicable rules of contract law.
The business must distinguish the mere recording of an order from assumption of a final contractual obligation where that distinction is lawfully provided for by the store's actual process.
Where the order does not result in conclusion of a contract, the Seller must deal with any amounts collected in accordance with the lawful basis for the payment and the obligations applicable to the particular transaction.
Non-acceptance of an order does not confer a general right to retain an advance payment or another amount without a legal or contractual basis.
The Seller may not treat a contract that has already been concluded as remaining at an earlier stage solely in order to avoid performing obligations that have already arisen.
Where the Customer is a consumer, cancellation before conclusion of the contract must be distinguished from the separate statutory right of withdrawal that may be exercised after the contract has been concluded.
Legal basis: Articles 185 et seq. of the Greek Civil Code concerning offer and acceptance where Greek law applies; Article 11 of Directive 2000/31/EC concerning electronic orders; Articles 9–11 of Directive 2011/83/EU concerning the right of withdrawal.
46. Restricting automated tools' access to Customers' personal data
Information systems and automated tools used to operate the online store must obtain access only to information necessary for performing their particular lawful functions.
The business must distinguish product-catalogue management, content-generation and price-calculation processes from processes involving personal data relating to orders and payments.
A tool used exclusively to generate product descriptions should not, without a lawful need, have access to identity details, delivery addresses, financial data or other personal information of Customers.
The business applies appropriate technical and organisational measures for separating access rights, recording necessary actions and protecting data.
Where a third-party artificial-intelligence service provider is used, the actual data flows, purpose of processing and corresponding contractual obligations are assessed separately.
Use of a central management system for several online stores does not automatically create a right to unrestricted exchange of personal data between different businesses.
Legal basis: Article 5(1)(b) and (c), Articles 6, 25 and 32 of the GDPR concerning purpose limitation, data minimisation, data protection by design and security of processing.
47. Final confirmation of the order and clear acknowledgement of the obligation to pay
Before final submission of the electronic order, the Seller must provide the Customer with the material information relating to the particular transaction in a clear, prominent manner appropriate to the electronic means of communication being used.
This information includes, where applicable, the main characteristics of the selected products, the total price including applicable taxes and additional charges, and the other information that must be presented immediately before the submission of an order that entails an obligation to pay.
The checkout process must make it entirely clear that final submission of the order entails an obligation to pay the agreed price.
Where the order is completed by means of an electronic button or corresponding function, the relevant wording must comply with the requirements of applicable law so that the Customer expressly acknowledges that they are assuming an obligation to pay.
The Seller may not consider the consumer bound by an order where the mandatory requirements of Article 8(2) of Directive 2011/83/EU have not been complied with, where the particular transaction falls within their scope.
The final submission process must also enable the Customer to review the basic details of the order and correct input errors before the final stage of the transaction.
The business organises the recording of the order so that the agreed products, the actual amount payable and the material terms communicated to the Customer during the particular process can be identified.
Legal basis: Article 8(2) of Directive 2011/83/EU concerning the requirement for clear acknowledgement of the obligation to pay and the legal consequences of non-compliance; Articles 10 and 11 of Directive 2000/31/EC concerning the electronic ordering process and correction of input errors.
48. Strong customer authentication and additional electronic-payment confirmation procedures
For electronic transactions to which the relevant requirements of payment-services law apply, the payment-service provider applies strong customer authentication, subject to the lawful exemptions provided for by the applicable regulatory framework.
Strong authentication may be based on independent elements of knowledge, possession or biometric characteristics in accordance with the requirements applicable to the relevant service. The particular authentication method is determined by the competent provider and the applicable technical and regulatory conditions.
The Customer may need to complete the confirmation process through their bank, payment application or another appropriate mechanism supported by the relevant provider.
The appearance of an additional confirmation step does not automatically mean that payment has been completed. The status of the financial transaction is determined according to the information supplied by the competent payment provider.
If the authentication process is not completed successfully, the Seller may keep the order in a pending-payment status in accordance with the actual operation of the store and the terms of the particular transaction.
Failure of authentication does not give the Seller a general right to characterise the transaction as fraudulent or impose financial penalties without lawful cause. Where further investigation is required, the business cooperates with the competent payment-service provider in accordance with the available lawful procedures.
The Seller may not bypass mandatory strong-authentication mechanisms or ask the Customer to disclose secret access credentials in order to circumvent the security process.
Legal basis: Article 97 of Directive (EU) 2015/2366 and Commission Delegated Regulation (EU) 2018/389 concerning the technical requirements for strong customer authentication and the prescribed exemptions.
49. Allocation of customs-clearance responsibility in international B2B sales
In genuine B2B transactions involving the international transport of goods, the Seller and the professional buyer may agree specific commercial terms concerning delivery, customs clearance, import duties, taxes and other costs connected with the particular transaction.
The allocation of the relevant obligations must be clearly determined before the corresponding commercial agreement is concluded.
The parties may use an appropriate Incoterms 2020 rule, with a clear reference to the particular version of the rules and to the agreed place of delivery.
Use of a commercial rule does not replace binding customs provisions and does not automatically alter the identity of the person who bears obligations towards the competent customs or tax authorities.
The Seller must distinguish the private allocation of financial costs between the contracting parties from liability that may be imposed mandatorily on a particular customs debtor or declarant.
Legal basis: Articles 15 and 77 of Regulation (EU) No 952/2013 concerning information supplied to customs authorities and customs debt on importation. Incoterms 2020 are commercial rules of the International Chamber of Commerce and apply in accordance with the relevant contractual agreement.
50. Refunds through payment-service providers and compliance with statutory time limits
Where a lawful obligation arises to refund an amount of money to the Customer, the Seller must make the refund according to its cause, the applicable contractual terms and the specific requirements laid down by law.
The business may use the payment-service provider through which the original transaction was made so that the refund is processed with appropriate matching to the particular order.
In the event of lawful withdrawal by the consumer from a distance sales contract, the refund is made without undue delay and, as a rule, within fourteen days from the day on which the Seller was informed of the decision to withdraw.
The refund is made using the same means of payment as that used for the original transaction, unless the consumer has expressly agreed otherwise and does not incur any fees as a result of the refund.
Where the contract concerns the sale of goods, the Seller may, subject to the legal conditions, wait until the returned goods are received or until evidence of their return is provided, whichever occurs first.
This possibility does not apply without qualification in every refund case and does not permit withholding a refund where the law imposes a different obligation.
The Seller may not generally invoke the involvement of an external payment-service provider as a reason for indefinitely delaying the initiation or completion of the refund actions that the Seller itself is required to take.
Where a specific technical problem arises in carrying out the refund, the business examines the actual facts, cooperates with the competent provider and appropriately informs the Customer, without extinguishing its legal obligations.
A mandatory monetary refund may not be unilaterally replaced by a discount voucher, store credit or another future commercial benefit where this is not permitted by law.
Legal basis: Article 13(1)–(3) of Directive 2011/83/EU concerning the trader's obligations in the event of withdrawal, the means of reimbursement, the time limit and the conditions under which receipt of returned goods may lawfully be awaited.
51. Time limit for reimbursement following exercise of the right of withdrawal
Where the consumer lawfully exercises the right of withdrawal, the Seller must reimburse the payments that are required to be refunded under the particular contract and applicable provisions.
Reimbursement is made without undue delay and, as a rule, within fourteen days from the day on which the Seller was informed of the consumer's decision to withdraw.
The date on which the request is internally approved by the business's staff does not automatically constitute the starting date of the statutory reimbursement period.
In contracts for the sale of goods, the Seller may, subject to the prescribed legal conditions, wait until the returned goods are received or until evidence of their dispatch is supplied, whichever occurs first.
This possibility does not apply without qualification where the Seller has offered to collect the goods itself or where a specific provision requires different treatment.
The involvement of an external payment-service provider does not release the Seller from the obligation to take the reimbursement actions for which it is responsible in a timely manner.
Legal basis: Article 13(1)–(3) of Directive 2011/83/EU.
52. Shipping packaging, protection of goods and safe transport
The Seller organises the packaging of products it ships in a manner appropriate to the nature, dimensions, quantity and characteristics of the particular goods.
The packaging must provide reasonable protection against ordinary handling and transport conditions, taking into account the actual requirements of the selected shipping service.
For products with particularly sensitive external packaging or that may be damaged by moisture, pressure or other transport conditions, the business considers the use of appropriate protective materials.
If a particular product is subject to specific packaging or transport rules, the corresponding mandatory requirements apply.
Use of appropriate packaging does not automatically release the Seller from responsibility for loss of or damage to the goods before the risk is lawfully transferred to the consumer.
Where the Customer receives a product that has been damaged during transport, the Seller examines the incident and its applicable obligations independently of any possibility of bringing a claim against the transport company.
The business may retain lawfully available information concerning packaging and the condition of the goods before shipment, without the existence of such information automatically excluding proof of subsequent damage.
Legal basis: Article 20 of Directive 2011/83/EU and Articles 5–7 and 10 of Directive (EU) 2019/771 concerning conformity of goods and the seller's liability.
53. Shipment tracking number and electronic information to the Customer
Where the selected transport service provides a tracking number, the Seller may communicate the relevant number to the Customer so as to facilitate information about the progress of the shipment.
Tracking information may be displayed through the online store, the order account or the carrier's corresponding service.
The availability and frequency of updates to tracking information may depend on the carrier's actual functions and the circumstances of the particular shipment.
The Seller is not required to display every intermediate transport stage where the carrier does not provide such information. However, inaccurate information creating a misleading impression concerning the actual status of the order must not be displayed.
Recording a tracking number does not, by itself, constitute proof that the products were delivered to the Customer.
Likewise, a delivery status shown in the carrier's information system is assessed together with the actual details of the transaction and the applicable provisions governing transfer of risk.
Where the Customer disputes actual receipt of the shipment, the business examines the available information and cooperates with the carrier to investigate the incident.
Legal basis: Articles 18 and 20 of Directive 2011/83/EU. Where applicable, Articles 5 and 6 of the GDPR apply to the processing of personal data connected with shipment tracking.
54. Shipping costs and disclosure of available transport services
Shipping costs applicable to a particular order must be disclosed to the Customer before final submission of the order so that the Customer can assess the total financial burden of the transaction.
The business may offer different methods of transport, which may vary in price, estimated delivery time, service area and the additional services included.
Where transport costs depend on the destination country, weight, volume, order value or other objective factors, the corresponding charge must be appropriately presented as part of the purchasing process.
The Customer's selection of a particular shipping service is made from the options actually available for the particular order and the relevant destination.
If, after conclusion of the contract, it becomes necessary to use a different transport service, the business must consider the consequences for the agreed price, delivery time and other material elements of the transaction.
The Seller may not unilaterally impose an additional transport charge that is not lawfully provided for by the agreement or applicable provisions.
Legal basis: Article 6(1)(e) and (g) and Article 8 of Directive 2011/83/EU concerning shipping costs, delivery terms and prior information to the consumer.
55. Management of accidents and serious incidents related to product safety
Where the business receives information concerning an accident or other serious incident that may be connected with the safety of a product it has made available, it must assess the report and the obligations arising under applicable law.
The investigation process may include identification of the product, the batch, the actual circumstances of the incident and the relevant information necessary for assessment of the risk.
The Seller may cooperate with the manufacturer, importer, other economic operators involved and the competent authorities, in accordance with the obligations corresponding to its actual role.
Where an obligation applies to notify an accident through the Safety Business Gateway, the relevant action is taken in accordance with the prescribed conditions and responsibilities.
The business may not assume that every accident report automatically proves a product defect or establishes specific civil liability.
Likewise, it may not dismiss without examination reliable information that may give rise to an obligation to take safety measures.
Legal basis: Article 20 of Regulation (EU) 2023/988 concerning the reporting of accidents related to product safety.
56. Documentation of origin, product identification and traceability
The Seller organises the necessary retention of information concerning the origin of products it markets, taking into account the obligations applicable to the particular category of goods and its actual role as an economic operator.
Documentation may include supplier details, relevant commercial documents, product-identification codes, batch information and other data necessary for fulfilment of specific legal obligations.
Use of a central information system enables the business to organise the matching of products, suppliers and orders so that it can deal more effectively with safety incidents, recalls or other situations requiring identification of particular goods.
The obligation to retain particular information and the period for which it must be kept are determined by applicable law and the actual needs of the relevant activity.
The business may not assume that the existence of any tax document automatically proves a product's compliance with all safety, labelling or marketing requirements.
Where traceability information is linked to Customers' personal data, the relevant processing is carried out in accordance with the lawful bases and requirements for protecting such data.
Legal basis: Articles 9–12 of Regulation (EU) 2023/988 concerning the obligations of the relevant economic operators and management of product information, together with specific traceability obligations applicable by category of goods.
57. Currency-conversion errors, different currencies and the actual payment amount
The Seller may display product prices in more than one currency where this assists Customers making transactions from different countries or using different means of payment.
Presentation of a price in another currency must enable the Customer to know the currency in which the transaction is carried out and the actual amount payable to the Seller before final submission of the order.
Where automated currency-conversion mechanisms are used, the business takes steps to ensure that the calculations are made in accordance with the stated conversion method and to avoid discrepancies between the price displayed in the catalogue, the electronic cart and the final payment amount.
The exchange rate applied by a bank, card issuer or independent payment-service provider may differ from the indicative rate used by the online store. Where required, the Customer is informed of the transaction currency and the possibility that currency conversion may be applied by the relevant provider.
The Seller does not automatically assume responsibility for every exchange-rate movement or charge independently imposed by the Customer's payment-service provider. This does not exclude the Seller's liability for inaccurate presentation of the agreed price, an incorrect charge resulting from its own system or failure to provide mandatory information.
Where an objective technical currency-conversion error is identified, the business examines the particular transaction on the basis of the currency agreed, the actual amount paid, the stage of contract formation and the applicable provisions.
The existence of a currency-conversion error does not confer a general right unilaterally to increase the price of a contract already concluded and does not justify retaining an amount collected without a legal or contractual basis.
Legal basis: Article 6(1)(e) and Article 8(2) of Directive 2011/83/EU concerning information on the total price and the payment obligation. Articles 45 and 59 of Directive (EU) 2015/2366 concerning information on payment services and currency conversion to the extent applicable to the providers involved.
58. Receipt of a damaged parcel and procedure for investigating the damage
Where the Customer receives a parcel whose external packaging or contents show visible damage, the Customer may inform the Seller through the available communication channels.
The business may request appropriate information concerning the condition of the shipment, such as a description of the damage and available photographic material, to the extent necessary and reasonable for investigating the incident.
The possibility of collecting photographs or other evidence must not be used as a disproportionate obstacle to the exercise of the Customer's statutory rights.
Damage to the external packaging does not automatically mean that the product itself lacks conformity. Likewise, the absence of visible external damage does not exclude the possibility of damage or a defect in the goods contained in the parcel.
The business examines the actual condition of the products, the information relating to the particular order and the applicable provisions.
Where it is established that the delivered product does not conform to the contract, the corresponding rights of the Customer arising from the lack of conformity apply.
The Seller may not generally exclude the relevant claims solely because the Customer did not make a reservation to the carrier upon receipt, where such a condition would restrict mandatory consumer rights.
Legal basis: Article 20 of Directive 2011/83/EU and Articles 5–7 and 13–16 of Directive (EU) 2019/771.
59. Pending transactions, temporary reservation of funds and distinction from final collection
During the electronic payment process, a temporary reservation of an amount, a check of available funds or another intermediate procedure may take place before final execution and settlement of the transaction.
The appearance of a reserved amount in the Customer's bank account or on the Customer's card does not automatically mean that the corresponding amount has been finally credited to the Seller.
The Seller may receive information concerning the payment status from the competent payment-service provider in order to determine whether the transaction has been authorised, executed, rejected, cancelled or remains in another intermediate status.
Where the Customer reports that an amount appears to be reserved without a corresponding confirmation that the order has been completed, the business examines the available information and cooperates with the payment provider to the extent necessary to investigate the incident.
The business should not require a second payment as a completed new transaction without first properly examining the actual status of the original payment where there is a specific indication of a possible double collection.
If the temporary reservation does not become a final charge, release of the funds takes place in accordance with the procedures and legal obligations of the competent providers. The Seller cooperates appropriately where action on its part is required to release a pending authorisation.
A temporary reservation of funds does not extinguish the Customer's rights relating to the actual purchase agreement and does not independently create a right for the Seller to collect an additional amount without a legal or contractual basis.
Legal basis: Articles 64 and 75 of Directive (EU) 2015/2366 concerning authorisation of transactions and blocking of funds in connection with card-based transactions, to the extent applicable to the particular payment service.
60. Review of required information and safety warnings before product publication
Before making a particular product available through the online store, the Seller must examine the safety and information requirements applicable to the actual category of the goods.
Where the product falls within the scope of Regulation (EU) 2023/988, the online offer must contain the information required by Article 19 of the Regulation.
Such information may include the prescribed details of the manufacturer, the relevant responsible person, product-identification characteristics and the required warnings or safety information.
The Seller must examine whether specific provisions apply to the particular goods that supplement or modify the general safety requirements.
The existence of a commercial description created by a supplier or automated system does not replace the required safety information.
The business may suspend publication or offering of a particular product where it does not possess the information legally required for the particular offer.
Legal basis: Articles 5, 9, 11, 12 and 19 of Regulation (EU) 2023/988, depending on the actual role of the economic operator and the scope of the Regulation.
61. Verification of actual availability, ability to perform and order confirmation
The Seller may use appropriate technical and organisational processes to verify the actual availability of products included in a particular order and the ability to perform that order in accordance with the agreed terms.
The verification may include confirmation of available stock, matching the selected products to the actual codes and quantities, payment status, available shipping services and legal restrictions that may apply to the ordered goods.
Where performance of a particular order depends on an external supplier, the business may carry out the necessary verification of availability information provided by the corresponding partner.
The existence of an automated product-import and updating mechanism does not exempt the Seller from the obligation to present the material information in its commercial offer accurately and to perform contracts it has lawfully concluded.
If the order has not yet become binding under the particular contract-formation process, the Seller examines whether it can be accepted on the basis of the actual circumstances and the information already communicated to the Customer.
If, on the other hand, the contract has already been concluded, a subsequent availability check does not confer a general right unilaterally to cancel the contract, substitute products or extend the agreed delivery period indefinitely.
The Seller takes steps to ensure that verification procedures are completed without undue delay and that the Customer is appropriately informed where an actual issue arises that materially affects performance of the transaction.
Legal basis: Article 6(1)(g) and Article 18 of Directive 2011/83/EU concerning agreed terms and the delivery period for goods. Article 11 of Directive 2000/31/EC concerning electronic recording and acknowledgement of receipt of an order.
62. Access to the website and availability of electronic services
The Seller makes reasonable efforts to maintain the functionality of the online store and access to the information necessary for carrying out transactions, tracking orders and communicating with the business.
Operation of the website depends on technical infrastructure, hosting services, telecommunications networks, software and other electronic services that may be affected by temporary malfunctions, maintenance work or unforeseen technical incidents.
The business may take reasonable measures to temporarily suspend particular electronic functions where this is required to protect security, data integrity or the proper operation of the store.
Temporary unavailability of the website does not automatically extinguish contractual obligations already undertaken or deprive the Customer of rights arising from a completed order.
Where a technical incident materially affects performance of a particular transaction, the Seller must address its consequences in accordance with the actual circumstances, the contractual terms and applicable law.
Legal basis: Article 18 of Directive 2011/83/EU concerning delivery of goods; Article 32 of Regulation (EU) 2016/679 concerning the security and ability to restore systems processing personal data. These provisions do not establish a general guarantee of uninterrupted operation of every website.
63. Accepted payment methods and conditions for completion of the financial transaction
The Seller enables the Customer to pay for orders using the payment methods displayed as available during the checkout process. The methods offered may include, as applicable, payment by debit or credit card, bank transfer or other lawful payment services supported by the online store.
Availability of a particular payment method may depend on the nature of the transaction, the actual amount of the order, the technical capabilities of the payment-service provider and the legal restrictions applicable to the particular case. Any restriction must be applied in accordance with the mandatory provisions governing acceptance of payment instruments and transactions between consumers and businesses.
The Customer is informed of the available payment methods and the material conditions for their use before final submission of the order. The business may not present a particular method as available and then impose undisclosed additional obligations or charges in breach of the law.
Choosing a particular payment method entails application of the processes required to carry out the corresponding transaction. Where payment is made through an independent licensed provider, the legal requirements for identification, authorisation and execution applicable to the particular service apply.
The Seller may organise performance of the order on the basis of the actual payment status in accordance with the terms disclosed to the Customer. The existence of a pending or failed payment is not automatically regarded as evidence of malicious conduct by the Customer and does not give the Seller a general right to impose arbitrary financial penalties.
In the event of a dispute concerning completion of the payment, the parties may use the available order data, transaction identifiers and confirmations from the relevant provider, without prejudice to the specific rights and obligations laid down by payment-services legislation.
Legal basis: Article 6(1)(e), Article 8(3) and Article 19 of Directive 2011/83/EU concerning information about the total price, accepted payment methods and charges for their use. Articles 64 and 97 of Directive (EU) 2015/2366 concerning authorisation of payment transactions and strong customer authentication.
64. Additional charges, optional services and express Customer consent
The Seller may offer additional services or optional commercial choices connected with a particular order provided that the corresponding benefit and its cost are appropriately disclosed to the Customer.
Where an additional payment concerns a service or benefit beyond the Seller's main contractual obligation, the consumer's express consent is required where provided by applicable law.
The business may not assume that the Customer accepted an additional payment solely because they failed to deselect a pre-selected option that had been activated automatically during checkout.
Optional services must be presented in a manner enabling the Customer to distinguish the main order price from the additional cost associated with the particular choice.
If an amount is collected for an optional service without the required express consent, the corresponding legal consequences apply, including the right to reimbursement of that payment where provided for.
General acceptance of the Terms and Conditions does not replace the specific consent required for a particular additional payment.
Legal basis: Article 22 of Directive 2011/83/EU concerning additional payments and Article 6(1)(e) of the same Directive concerning prior information on the total price of the transaction.
65. Unforeseen import charges and allocation of customs costs
Where a particular order is destined for a country outside the European Union or is subject to a special import procedure, customs, tax or other mandatory charges may arise.
The Seller must provide the information required concerning the actual cost of the transaction and the possibility of additional charges applying, in accordance with the legal conditions.
In professional transactions, a specific allocation of customs-clearance and import costs may be agreed provided that the corresponding agreement is clear and permitted by law.
The existence of an unforeseen import charge does not automatically give the Seller the right to impose any additional amount on the Customer after conclusion of the contract.
The consequences are assessed by reference to the agreed allocation of costs, the statutory information obligation and the actual cause of the charge.
Legal basis: Article 6(1)(e) of Directive 2011/83/EU concerning prior information on the total price and additional charges; Regulation (EU) 952/2013 concerning the relevant customs obligations.
66. Unauthorised payment transactions, dispute of authorisation and payer rights
Where the Customer claims that a particular payment transaction was carried out without the required authorisation, the corresponding dispute is examined in accordance with the applicable payment-services framework and the lawful procedures of the competent provider.
The existence of a recorded order in the online store does not, by itself, constitute conclusive proof that the actual holder of the payment instrument used had authorised the particular financial transaction.
Likewise, successful completion of a particular technical authentication process is not, by itself, sufficient to prove that the payer acted fraudulently or with gross negligence.
The Customer may notify the dispute to the competent payment-service provider in accordance with the legal conditions and time limits applicable to the particular case.
The Seller cooperates, to the extent required, with the payment-service provider in supplying lawfully available information connected with the commercial transaction, without replacing the responsibilities or obligations that the law assigns to the provider itself.
The business may not require the Customer first to prove fraud by a third party as a general condition for exercising rights provided by the law governing unauthorised payment transactions.
Where the dispute concerns a particular commercial order, the lawfulness of the financial transaction must be distinguished from the issue of actual delivery of the goods and the existence or otherwise of a binding purchase contract.
The business retains the ability to pursue its lawful claims on the basis of the actual facts without unilaterally altering the mandatory allocation of liability and burden of proof provided for by payment-services law.
Legal basis: Article 64 of Directive (EU) 2015/2366 concerning authorisation of payment transactions, Article 71 concerning notification of unauthorised or incorrectly executed transactions, Article 72 concerning evidence of authorisation and execution, Article 73 concerning the provider's liability and Article 74 concerning the payer's liability.
67. Chargeback disputes, protection against unfounded claims and documentation of the actual transaction
The Customer retains the right to dispute a particular charge through the competent payment-service provider in accordance with applicable law and the rules governing the relevant payment instrument.
The dispute may concern an unauthorised transaction, an incorrect amount charged, non-receipt of the agreed goods, products different from those ordered or another ground recognised by the applicable legal or contractual framework.
The Seller retains the right to examine the actual basis of the dispute and submit to the competent provider the necessary and lawfully available evidence documenting the occurrence and performance of the particular transaction.
Such evidence may include the order record, date and amount of payment, products ordered, agreed quantities, transaction confirmation, dispatch and delivery details and relevant communication with the Customer.
The business may contest a chargeback request where it holds specific evidence supporting that the transaction was carried out and performed in accordance with the contract. This right is exercised through the lawful procedures and actually available mechanisms of the competent provider.
Submission of a chargeback request does not, by itself, constitute proof of fraud, malicious conduct or an unjustified claim by the Customer. Likewise, initial approval of a payment does not automatically prove that the Seller has fulfilled all contractual obligations.
Where the business has specific evidence that the Customer knowingly made a false statement with the aim of obtaining an unjustified refund, it retains the ability to consider exercising its lawful rights according to the actual circumstances and applicable provisions.
The business may not automatically impose a fine, additional charge or another financial penalty solely because a chargeback request has been submitted. Any claim for compensation for actual loss must have an appropriate lawful or contractual basis and must be proven under the applicable rules.
The chargeback-dispute procedure does not extinguish the Customer's legal rights concerning withdrawal, lack of conformity of goods or non-performance of the contract.
Legal basis: Articles 71–74 of Directive (EU) 2015/2366 in relation to unauthorised or incorrectly executed payment transactions. Other chargeback procedures are also governed by the applicable rules of the relevant card scheme and contractual relationships with payment-service providers.
68. Evidence of dispatch and delivery, verification of receipt and handling disputed deliveries
The Seller organises an appropriate process for recording and retaining information connected with dispatch and delivery of products so that performance of the particular order can be documented.
The relevant information may include the order number, shipment number, date on which the parcel was handed to the carrier, selected transport service, tracking information and available proof of receipt.
Where delivery is carried out through an independent transport company, the Seller may use the information supplied by the relevant service to track the shipment and investigate actual incidents of loss, delay or disputed delivery.
A “delivered” status appearing in the carrier's system is evidence that may be taken into account when investigating the transaction, but it is not automatically regarded as irrebuttable proof that the parcel was in fact delivered to the Customer or to a person lawfully designated as recipient.
Where the Customer states that a particular order was not received, the Seller examines the available delivery information, the carrier's information and the actual circumstances of the particular shipment.
The business may request from the carrier additional information necessary for the investigation, such as confirmation of the place of delivery, receipt details or other information that may lawfully be provided.
The existence of a signature or other proof of receipt is assessed in light of the actual circumstances and does not automatically exclude the possibility of a delivery error, receipt by an unauthorised person or another objective defect in performance.
The Seller may not automatically transfer the risk of loss of or damage to the goods to the consumer solely because the parcel was handed to a carrier offered by the Seller as an available shipping option.
Where it is established that the products were not delivered in accordance with the contract and applicable provisions, the business must deal with the incident in accordance with its actual contractual obligations and the Customer's legal rights.
Legal basis: Article 18 of Directive 2011/83/EU concerning the obligation to deliver and Article 20 of the same Directive, which governs transfer of the risk of loss of or damage to the goods to the consumer.
69. Claims of natural origin, unbleached materials and product composition
The Seller may use commercial-description terms referring to the composition, origin or processing of a product's materials provided that the corresponding information reflects the actual characteristics of the goods.
Terms such as “natural”, “unbleached”, “free from a particular additive”, “made from plant fibres” or similar indications must be presented accurately and must not create a broader impression than can be substantiated.
Use of a particular material or production method does not automatically permit attribution of additional health, safety or environmental-superiority properties where those properties are not independently substantiated.
The Seller may rely on appropriate manufacturer information, technical documents or other reliable documentation when presenting the composition characteristics of the product, without prejudice to its obligation to avoid misleading commercial practices.
Where a particular claim derives solely from a commercial statement by the manufacturer and is not an independently verified certification, its presentation must not create the impression that a separate assessment has been carried out or that official certification has been granted.
If particular information concerning the composition or processing of a product is found to be inaccurate, the Seller examines the need to correct the listing and the consequences for the corresponding transactions.
Legal basis: Article 6(1)(b) and Article 7 of Directive 2005/29/EC concerning misleading statements and omissions about product composition and characteristics; Articles 6 and 7 of Directive (EU) 2019/771 concerning conformity of goods with the contract and their objectively expected characteristics.
70. Obvious technical pricing errors and procedure for dealing with them
The Seller may use automated information systems to update commercial prices, import products from suppliers and calculate the amounts displayed in the online catalogue.
Despite appropriate control procedures, technical errors, inaccurate entries or other malfunctions affecting the displayed price of a particular product may occur.
Where an objectively obvious pricing error is identified, the business examines the particular transaction on the basis of the actual cause of the error, the information communicated to the Customer and the stage reached in the contract-formation process.
The mere fact that the displayed price is lower than the usual commercial price does not automatically mean that an obvious technical error exists or that the Seller has an unrestricted right to cancel the transaction.
Where the error is identified before conclusion of a binding contract, the Seller appropriately informs the Customer and examines whether the relevant offer can be corrected in accordance with applicable law.
If the contract has already been concluded, the possibility of relying on a particular error and the corresponding legal consequences are determined by the actual circumstances and the applicable provisions concerning contracts and mistake.
The Seller may not use a general technical-error clause as a means of arbitrarily cancelling binding orders or unilaterally changing agreed prices.
Legal basis: Articles 140 et seq. of the Greek Civil Code concerning mistake in declarations of intention where applicable to the particular transaction, together with Articles 3 and 6 of Directive 93/13/EEC concerning unfair contractual terms.
71. Customer contact details and order-related information
During checkout, the Customer provides appropriate contact details so that the Seller can send the information necessary for recording, performing, paying for and delivering the particular order.
The business may use these details to send order confirmations, provide information on material changes to the transaction, communicate concerning actual delivery problems and fulfil its other contractual and legal obligations.
Communications necessary for performance of the contract must be distinguished from separate commercial or advertising communications, to which the corresponding specific rules apply.
Providing an email address or telephone number for management of a particular order does not automatically constitute general consent to every form of advertising communication.
The Seller must use the contact details in accordance with the specific lawful purposes for which they were collected and avoid disclosing them to third parties for independent activities not covered by an appropriate lawful basis.
Where communication is carried out through a third-party provider, such as a transport company or technical messaging service, the corresponding processing of personal data is organised according to the actual roles and applicable obligations of the entities involved.
The Customer may use the store's published means of communication to request information about the order and exercise rights granted by applicable law.
Legal basis: Articles 5, 6, 13 and 28 of the GDPR, as applicable, concerning lawful processing, information and relationships with processors. Article 13 of Directive 2002/58/EC concerning unsolicited commercial communications.
72. Central register of legal restrictions and compliance documentation
The business may use a central information system to organise information concerning the lawfulness of making its products available, safety requirements and specific restrictions applicable in particular countries or forms of commercial activity.
The register may include the actual category of each product, the countries in which the possibility of marketing it is being assessed, the relevant legal sources, review dates and the specific obligations associated with the particular category.
The business may also retain information concerning the origin and authenticity of products, required safety information, relevant licences for the use of commercial material and procedures for handling compliance incidents.
The existence of a central register does not replace actual application of the law and does not release the Seller from the obligation to assess a particular transaction where special requirements apply.
The information in the register must be appropriately updated when factual circumstances, the classification of a product or the applicable regulatory framework change.
Where the keeping of the relevant records involves personal data of natural persons, the processing must be carried out in accordance with the requirements of lawfulness, data minimisation, security and storage limitation.
Legal basis: Articles 9–12 and 19 of Regulation (EU) 2023/988 to the extent applicable to the actual economic operator, and Articles 5, 6 and 32 of Regulation (EU) 2016/679 where management of the register involves personal data.
73. Lawfulness of making products available on the Italian market
The possibility of making products available to consumers located in Italy must be assessed separately from the ability to access the website or use the Italian-language version of the online store.
The Seller must take account of the specific provisions applicable in the Italian market, including restrictions that may concern particular product categories, cross-border distance sales, importation, commercial promotion and tax treatment.
The fact that a particular product may lawfully be made available in Greece is not, by itself, sufficient to establish a right to sell it online or ship it to Italy where different specific rules apply.
The business must distinguish between product categories and must not assume that a restriction applying to particular tobacco products or other specially regulated categories automatically applies, without individual assessment, to every related item.
Likewise, commercial presentation of a product as an accessory does not release the Seller from the obligation to classify the particular item correctly in legal terms.
Where the possibility of lawful online sale or shipment of a particular product to Italy has not been confirmed, the business must not present the corresponding transaction to the Customer as unconditionally available.
Legal basis: Article 18 of Directive 2014/40/EU and the corresponding specific Italian provisions applicable by product category. This provision requires a separate review of Italian law for each product before enabling shipment.
74. Incorrect, defective and non-conforming products — distinction from ordinary withdrawal
Where the Customer receives a product different from that agreed, a product with a material discrepancy in quantity or characteristics, or goods showing another lack of conformity, the corresponding rules of the law on the sale of goods apply.
Rights arising from a lack of conformity must be distinguished from the separate right of withdrawal from a distance contract.
The consumer is not required to characterise a request for remedy of a defective product as an ordinary withdrawal in order to seek application of statutory rights.
Where a lack of conformity is established, the Seller must examine the available remedies, including repair, replacement, proportionate price reduction or termination of the contract, subject to the specific statutory conditions.
Remedy of the lack of conformity is provided without imposing costs on the consumer where required by law.
The business may not rely on expiry of the ordinary withdrawal period as a general reason for excluding rights arising from the Seller's statutory liability for lack of conformity.
Legal basis: Articles 5–16 of Directive (EU) 2019/771, in particular Articles 10 and 13–16.
75. Confirmation of receipt of a withdrawal statement and documentation of submission time
Where the consumer exercises the right of withdrawal through the prescribed electronic function, the Seller must send confirmation of receipt of the relevant statement on a durable medium without undue delay.
The confirmation must include the content of the statement and the date and time of its submission in accordance with the specific requirements of applicable law.
The business may use an automated system for recording and sending the relevant confirmations provided that the process corresponds to the actual submission of the statement.
Electronic confirmation of receipt must be distinguished from the internal assessment of the consequences of the particular withdrawal.
The Seller may not consider that withdrawal was exercised on a later date solely because the relevant statement was reviewed by business staff at a later time.
Where the statement was submitted in time through the prescribed electronic function, the time of submission is assessed in accordance with the specific rules of Article 11a.
The business must retain the necessary process records in accordance with applicable security and personal-data-protection requirements.
Legal basis: Article 11a(4) and (5) of Directive 2011/83/EU, as inserted by Directive (EU) 2023/2673.
76. Age restrictions and verification of the ability to make a lawful purchase
Where the sale of a particular category of products is subject to a statutory minimum age, the Seller must apply the requirements applicable to the particular transaction and to the country in which the product is made available.
A general statement by a visitor that the visitor is an adult is not automatically regarded as a sufficient verification process in every case, particularly where specific legislation requires a particular method of determining age.
The relevant checks must be carried out in a manner appropriate to the nature of the product, the applicable regulatory framework and the actual possibilities for making it lawfully available.
Where collection of personal data is required for age verification, processing must be limited to information necessary to fulfil the relevant legal obligation and must be carried out in accordance with personal-data-protection rules.
The business is not required to collect copies of identity documents or other extensive personal data where the relevant legislation does not require this and the purpose can be achieved through a less intrusive lawful method.
Where the mandatory age check cannot be carried out, the corresponding transaction is not completed in breach of the applicable requirements.
Legal basis: Article 18(4) of Directive 2014/40/EU concerning the prescribed age-verification checks for covered cross-border distance sales where such sales are permitted, and Articles 5 and 6 of the GDPR concerning data minimisation and lawful processing of personal data.
77. Available delivery countries and actual shipping scope
The Seller determines the countries and geographical areas to which it provides shipping services, taking into account the nature of the products, availability of transport services, actual commercial capabilities and applicable legal obligations.
Access to the website from a particular country does not automatically mean that the Seller undertakes to deliver every product to that country.
Available destinations and shipping restrictions must be presented clearly and must not conflict with the options offered during checkout.
Where a particular product cannot lawfully be shipped to a certain country, the business must address the corresponding restriction as part of its actual commercial operation rather than relying solely on a general disclaimer.
Where a new legal or factual circumstance affects the ability to ship to a particular destination, the Seller may amend the available options for future transactions.
Changing the available delivery countries does not automatically extinguish obligations already undertaken. Pending orders are dealt with in accordance with the particular contract and applicable legislation.
Legal basis: Article 6(1)(g) of Directive 2011/83/EU concerning prior information on delivery arrangements, and Article 18 concerning performance of the contractual delivery obligation.
78. Country of production, manufacture and commercial origin of products
Information concerning the country of production, place of manufacture, geographical origin or commercial origin of a particular product must correspond to the actual and appropriately documented facts relating to the goods.
The Seller may present relevant information provided by the manufacturer, supplier or accompanying product documentation provided that it does not create an inaccurate or misleading impression concerning the product's actual origin.
The country in which the supplier, distributor or commercial representative is established does not automatically coincide with the country in which the product was manufactured. Likewise, the country from which the goods are shipped does not, by itself, prove their production origin.
The commercial presentation must distinguish those concepts where the information may affect the Customer's purchasing decision or where specific legislation requires a particular indication of origin.
The Seller is not required to attribute to every product a geographical designation that is not required by law or does not constitute material information for the particular transaction. If, however, the Seller chooses to make a particular origin claim, that claim must be accurate and capable of being substantiated.
Where it is established that a product was presented with an inaccurate geographical or commercial origin, the business examines the need to correct the listing and the consequences for affected transactions.
Legal basis: Article 6(1)(b) of Directive 2005/29/EC, which includes geographical and commercial origin among the characteristics capable of being the subject of a misleading commercial practice; Article 7 of the same Directive concerning omission of material information.
79. Choice of carrier, cooperating shipping companies and responsibility for performing delivery
The Seller may cooperate with postal services, courier companies, freight carriers and other lawful providers of goods-transport services in order to fulfil orders placed through the online store.
Available shipping services may differ depending on the country of destination, weight, dimensions, value and nature of the products and other actual parameters of the particular transaction.
The Customer is informed of material information connected with the selected service, including applicable shipping costs and the agreed or estimated delivery time.
Entrusting physical transport of the goods to an independent carrier does not automatically release the Seller from contractual obligations undertaken towards the consumer.
Where the carrier has been selected from among the services offered by the Seller, the risk of loss or damage to the goods passes in accordance with the applicable provisions and not merely when the parcel is handed to the transport company.
Where the Customer independently entrusts transport to a carrier not included among the options offered by the Seller, the specific rule applicable to that case is considered.
The Seller retains its lawful rights against the carrier in respect of damage, loss or other deficiencies in performance of the transport service, without exercise of those rights constituting a general prerequisite for satisfying the corresponding statutory claims of the consumer.
Legal basis: Article 20 of Directive 2011/83/EU concerning transfer of the risk of loss or damage to goods.
80. Electrical devices, batteries and products subject to specific safety requirements
Where the online catalogue includes electrical or electronic devices, products with built-in or removable batteries and other goods subject to particular technical or regulatory requirements, the Seller must examine the applicable obligations before making them available on the market.
The existence of a general commercial description or a supplier's statement does not automatically replace required markings, identification details, safety warnings or conformity documentation applicable to the particular product category.
Where required, the business must retain or ensure access to necessary manufacturer information, the prescribed responsible economic operator and instructions relating to use, charging, storage, transport and safe disposal of the product.
Presentation of the device must avoid inaccurate claims concerning technical characteristics, battery life, compatibility or certifications.
Where a particular device or battery is subject to specific transport restrictions, the business examines whether it can lawfully be shipped through the selected transport service.
If reliable information arises concerning a defect or risk associated with a particular device, the Seller takes the measures corresponding to its actual role in the distribution chain and the applicable safety obligations.
Legal basis: Regulation (EU) 2023/988 on general product safety, Regulation (EU) 2023/1542 concerning batteries and waste batteries, and the specific harmonisation provisions applicable to the particular electrical or electronic device.
81. Multi-packs, boxes and wholesale commercial units
Where a product is offered in a multi-pack, commercial box or other composite sales unit, the description must clearly specify the actual quantity of products contained and the material characteristics of the particular offer.
The price displayed in the online catalogue must correspond to the actual sales unit selected by the Customer and must not create confusion between individual products, multi-packs and larger commercial quantities.
Where the same product family is available in different quantities, the relevant options must be presented with sufficient distinction so that the order reflects the buyer's actual intention.
The business may apply special commercial prices for larger quantities or professional transactions provided that the corresponding terms are appropriately disclosed and do not create a misleading impression concerning the quantity or total price.
Delivery of a smaller quantity than agreed is not automatically treated as a mere commercial variation but is assessed under the provisions governing performance of the contract and conformity of goods.
Legal basis: Articles 5 and 6 of Directive (EU) 2019/771; Article 6(1)(a) of Directive 2011/83/EU; Articles 6 and 7 of Directive 2005/29/EC concerning misleading commercial practices and omissions.
82. Total amount payable and final financial burden of the order
Before final submission of the order, the Customer must be clearly informed of the total amount payable under the particular transaction.
The total amount includes the price of the selected goods, applicable tax charges, prescribed shipping costs and any other charge that must be disclosed under the applicable legislation.
Where a particular additional cost cannot reasonably be calculated in advance, the business must provide the required information concerning the method by which it is calculated or the possibility that it may be imposed, subject to the legal conditions.
The checkout process must allow the Customer to review the products, quantities, selected services and corresponding amount payable before assuming the payment obligation.
The Seller may not impose undisclosed additional mandatory charges by relying on a general contractual statement that does not satisfy the requirements for clear pre-contractual information.
Completion of payment does not extinguish the Customer's rights where it is established that a particular charge was imposed without a legal or contractual basis.
Legal basis: Article 6(1)(e), Article 8(2) and Article 22 of Directive 2011/83/EU concerning the total price, payment obligation and additional payments.
83. Commercial offers, promotional activities and participation conditions
The Seller may carry out commercial offers, promotional activities and special product-sales programmes, provided that the corresponding activities are permitted by the law applicable to the particular category of goods and the market to which the offer is directed.
Promotional activities may include, as applicable, reduced prices, special multi-pack prices, limited-time offers, loyalty programmes or other lawful commercial benefits in accordance with the conditions communicated to the Customer.
The business must clearly present the material terms of each offer, including its duration, participating products, participation conditions and any restrictions that may affect the ability to benefit from it.
Where the promotion concerns a specific quantity of products or a limited period, the corresponding presentation must reflect the actual circumstances and must not create a misleading impression of artificial scarcity or urgency to purchase.
The Seller may modify or discontinue a promotion for future transactions in accordance with its published terms and applicable law. Subsequent discontinuation of the offer does not automatically alter the agreed price or other material terms of a contract already concluded.
For products subject to specific restrictions on advertising, commercial promotion or the provision of financial incentives, the business applies the corresponding specific provisions before activating any promotional activity.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning misleading commercial practices and omissions, and Article 6a of Directive 98/6/EC where the promotion includes an announcement of a price reduction.
84. Replacement of an ordered product and prohibition of unilateral changes to agreed characteristics
The Seller is required to deliver the product agreed with the Customer in accordance with the actual description, selected version, quantity, quality and other material characteristics of the particular transaction.
The existence of a different product of the same brand or a similar category does not automatically give the Seller the right to replace the product originally ordered.
Replacement may be proposed, for example, where a particular product is unavailable, production has been discontinued or the manufacturer offers a different version with corresponding characteristics.
The proposal must allow the Customer to know the actual differences between the product originally ordered and the proposed substitute, including any differences in quantity, packaging, composition, dimensions or price.
Acceptance of a different product takes place in accordance with the rules governing the particular amendment to the contract. The Customer's silence is not automatically treated as consent where the applicable legislation or the nature of the transaction requires a different process.
Where the Seller delivers a different product without the required agreement and the delivered goods do not conform to the contract, the corresponding rights of the Customer arising from lack of conformity apply.
A higher commercial value of the substitute product does not automatically mean that the replacement conforms to the contract or that the Customer is obliged to accept the different goods.
Legal basis: Articles 5–7 of Directive (EU) 2019/771 concerning conformity requirements for goods and Articles 13–14 of the same Directive concerning available remedies.
85. Procedure for contesting decisions restricting or excluding access to online platforms
Where the Seller uses a third-party online platform for commercial presentation or sale of products, the corresponding activity is subject to the applicable legal rules and the contractual terms of the particular service.
Where a product is removed, visibility is restricted, a professional account is suspended or another decision affects access to the platform, the business may examine the reasons for the decision and the available means of challenging it.
Where the service falls within the scope of the relevant provisions of Regulation (EU) 2019/1150, the corresponding requirements concerning restriction, suspension and termination of services to business users apply.
Where the corresponding provisions of the Digital Services Act apply, the business may use the prescribed procedures concerning statements of reasons and challenges to content-restriction decisions.
The existence of a right to challenge a decision does not mean that the platform is required to permit the sale of a product that is prohibited by law or breaches applicable contractual rules.
The Seller may collect the necessary information documenting its lawful activity and submit it through the corresponding available procedures.
Legal basis: Articles 4 and 11 of Regulation (EU) 2019/1150 and Articles 17, 20 and 21 of Regulation (EU) 2022/2065, depending on the type of service and the conditions for application.
86. Agreed delivery period and obligation to perform the contract on time
The Seller is required to deliver the ordered goods within the time agreed with the Customer and in accordance with the specific provisions applicable to the particular sales contract.
Unless the parties have agreed otherwise regarding the delivery time, the general obligation is to deliver without undue delay and, as a rule, within 30 days from conclusion of the contract in accordance with Article 18 of Directive 2011/83/EU.
The agreed period must take into account the actual preparation time, availability of products, selected transport service and other circumstances known when the contract is concluded.
The Seller may not unilaterally alter the agreed period by relying on a general clause concerning indicative delivery times where a specific binding obligation has been undertaken.
If delivery does not take place within the agreed time, the consumer has the rights laid down by the applicable legislation. As a rule, the consumer may call upon the Seller to make delivery within an additional period appropriate to the circumstances.
Where delivery is not made within that additional period, or where a lawful case for immediate termination of the contract exists, the consumer may exercise the corresponding rights.
The business must reimburse amounts due without undue delay where the contract is lawfully terminated because of non-delivery.
Legal basis: Article 18(1)–(4) of Directive 2011/83/EU.
87. Time of conclusion of the contract, acceptance of the order and distinction from an automated acknowledgement of receipt
The electronic ordering process is carried out through the store's available functions and includes selection of products, entry of necessary information, selection of available payment and delivery methods and final submission of the order by the Customer.
The time at which the sales contract is concluded is determined in accordance with the actual process for submission and acceptance of the order, the information communicated to the Customer before purchase and the applicable rules of contract law.
Automatic transmission of an electronic message confirming that the information system has received and recorded the order does not necessarily amount to final acceptance of the Customer's offer to conclude the contract.
If the store's actual process provides for a separate stage at which the order is accepted, that distinction must be clearly disclosed to the Customer before submission. The automated acknowledgement of receipt must correspond to the actual stage of the transaction and must not create a contradictory impression as to whether a binding contract has been concluded.
The Seller may not retrospectively characterise a contract already concluded as merely a pending order solely in order to avoid performing contractual obligations. Likewise, receipt of an order does not automatically require the Seller to accept an offer to purchase where, under the lawful and actual process of the transaction, the contract has not yet been concluded.
Acceptance or non-acceptance of a particular order must take place in accordance with the terms disclosed to the Customer, the actual circumstances and the mandatory provisions applicable to the transaction.
Legal basis: Article 11(1) of Directive 2000/31/EC and Article 10(1) of Greek Presidential Decree 131/2003 concerning electronic acknowledgement of receipt of an order without undue delay. Articles 185 et seq. of the Greek Civil Code concerning offer and acceptance in the formation of a contract where Greek law applies.
88. Changes to packaging and commercial presentation by the manufacturer
Manufacturers of products made available through the online store may alter the external appearance, graphic elements, design, commercial markings or other characteristics of their packaging.
The Seller may receive from lawful suppliers different batches of the same product that differ in the external appearance of the packaging without necessarily changing the nature, quantity or function of the goods contained within.
Where the modification concerns only non-material external characteristics, actual conformity of the product is assessed by reference to the agreement, its overall presentation and the significance of the particular difference for the purchase.
If, by contrast, the modification affects the quantity of products contained, composition, dimensions, functional characteristics or another material element of the agreement, the Seller must present the new version appropriately and avoid offering it as an entirely identical item where that could create a misleading impression.
Differences between old and new packaging do not extinguish the Customer's rights in the event of lack of conformity of the goods delivered.
The Seller retains the ability to update photographs, commercial descriptions and catalogue information in order to present accurately the products available at any given time.
Legal basis: Articles 6 and 7 of Directive (EU) 2019/771 concerning agreed and objectively expected characteristics of goods; Article 6(1)(b) of Directive 2005/29/EC concerning misleading presentation of the main characteristics of products.
89. Product recalls and obligations to inform affected Customers
In the event of a product recall for safety reasons, the Seller must assess the obligations applicable to its actual role and cooperate with the competent economic operators and authorities in order to address the incident effectively.
The business organises, to the extent required and permitted, the ability to identify the products and orders affected by the particular recall.
Where consumers who have acquired the affected product can be identified and a corresponding legal obligation applies, the relevant safety information is communicated appropriately and without undue delay.
If direct contact with all affected consumers is not possible, the business considers the additional methods of information provided for by applicable law and the corresponding recall procedures.
The information must enable the Customer to identify the affected product, understand the actual risk and know what action must be taken.
The recall process may not be used as a means of restricting the Customer's mandatory rights or imposing charges that are not permitted for dealing with the problem.
Legal basis: Articles 35–37 of Regulation (EU) 2023/988 concerning consumer information, the content of recall notices and remedies in the event of a recall for safety reasons.
90. Procedure for dealing with unfounded intellectual-property complaints
Where a complaint is submitted alleging that a particular photograph, description or other content of the online store infringes a third party's intellectual-property rights, the Seller may examine the actual substance of the complaint and the available evidence concerning lawful use of the material.
The business may provide appropriate evidence of creation, licensing or another lawful basis for use of the content through the procedures provided by the relevant service provider.
Where the complaint results in removal of content or another restriction by an online platform, the Seller may use the dispute procedures available under the applicable rules.
Submission of a complaint does not automatically mean that the alleged infringement has been established.
Likewise, the existence of a right to contest a complaint does not permit continued use of content where that use actually infringes third-party rights.
The Seller retains the ability to protect its rights lawfully against abusive or objectively false complaints in accordance with the actual circumstances and applicable law.
Legal basis: Articles 16 and 17 of Regulation (EU) 2022/2065 concerning notices of illegal content and statements of reasons for restrictions imposed by covered hosting-service providers.
91. Compatibility of products with devices, accessories and other goods
Where a product is intended to be used in combination with a particular device, accessory or other good, the Seller takes steps to ensure that material compatibility information is appropriately presented where it is necessary for the Customer's choice.
The description may include information concerning dimensions, connection type, function, technical requirements and other characteristics determining whether the particular product can be used with another product.
Reference to a particular brand or trade name for the purpose of describing compatibility does not automatically mean that the product offered is manufactured by that manufacturer or that an official relationship exists with it.
Where the Customer informs the Seller of a specific particular purpose before conclusion of the contract and the Seller accepts that the product is suitable for that purpose, the corresponding agreement is taken into account when assessing conformity of the goods.
The business is not required to guarantee general compatibility with every device or accessory available on the market where such compatibility does not arise from the actual characteristics, ordinary use or agreed terms.
Where the commercial presentation contains a specific statement of compatibility that proves inaccurate, the Seller examines the lack of conformity in accordance with the applicable provisions.
Legal basis: Article 6(1)(a) and (b) and Article 7 of Directive (EU) 2019/771 concerning compatibility and fitness for a specifically agreed purpose; Article 14(1)(c) of Regulation (EU) 2017/1001 concerning use of a trademark for identifying or referring to products subject to the conditions laid down therein.
92. Tax charges and presentation of the final price to the consumer
The selling price displayed to the consumer must include the tax charges required to be incorporated into the final price under the applicable legislation.
Where the particular transaction is subject to special tax treatment because of the nature of the product, place of delivery or other actual characteristics, the business must organise presentation of the price in accordance with the corresponding information obligations.
Display of a price excluding taxes in a consumer-sales environment must not create a misleading impression concerning the amount that the Customer will ultimately be required to pay.
Different methods of commercial price presentation may apply to professional transactions provided that they correspond to the actual status of the transaction and are not used to circumvent mandatory consumer-protection rules.
The tax treatment of the transaction is not determined solely by the language of the website, the domain extension or the store's trade name.
The actual Seller must fulfil the statutory tax obligations connected with the particular transaction and issue the corresponding required documents.
Legal basis: Article 6(1)(e) of Directive 2011/83/EU and Article 2 of Directive 98/6/EC concerning the definition of the selling price, together with the tax provisions applicable to the particular transaction.
93. Failed electronic transactions and lawful management of incomplete payment
Where an electronic payment is not successfully completed, the Seller may keep the corresponding order in an appropriate pending status in accordance with the actual operation of the store and the terms disclosed to the Customer.
Payment failure may result from insufficient available funds, rejection of authorisation, failure to complete additional authentication, a temporary technical malfunction or another actual cause connected with the particular transaction.
The business may not automatically assume that every failed transaction results from fraudulent or abusive conduct by the Customer. Assessment of any corresponding indication must be based on specific factual evidence.
The Seller may allow the Customer to retry the payment or select another available method provided that the process is permitted by the contract and the applicable provisions.
Before any new collection attempt, the business must take into account the actual status of the previous transaction in order to reduce the risk of double charging.
Where the order has not yet become binding or its performance lawfully depends on completion of payment, the consequences of non-payment of the agreed price are determined by the terms of the particular transaction and applicable law.
If the contract has already been concluded, incomplete payment is dealt with in accordance with the parties' actual contractual obligations. The business may not impose arbitrary penalties or retain amounts without a legal or contractual basis.
Legal basis: Articles 64 and 97 of Directive (EU) 2015/2366 concerning authorisation and authentication of payment transactions. Articles 6 and 8 of Directive 2011/83/EU concerning prior information and the process by which a payment obligation is assumed.
94. Right of withdrawal from a distance sales contract
A consumer who concludes a distance contract for the purchase of goods through the online store generally has the right to withdraw from the contract within the statutory period without being required to state the reason for the decision.
The right is exercised in accordance with the conditions of the applicable legislation and subject to the specific exceptions laid down for particular categories of contracts or goods.
The Seller must provide the consumer with the required information concerning the existence of the right, the period for exercising it, the available procedures and the statutory obligations arising from its exercise.
The existence of the store's commercial returns policy cannot restrict mandatory withdrawal rights granted by law.
The consumer is not required to prove that the product is defective or that the Seller breached a contractual obligation in order to exercise the statutory right of withdrawal.
Exercise of the right must be distinguished from the separate rights arising from lack of conformity of the goods or non-performance of the contract.
Where the consumer lawfully exercises the right of withdrawal, the corresponding obligations to return goods and reimburse money apply in accordance with the specific provisions governing the particular transaction.
Legal basis: Articles 9–16 of Directive 2011/83/EU concerning the right of withdrawal, the applicable periods, procedures and legal consequences.
95. Reimbursement of initial delivery costs and treatment of more expensive shipping services
In the event of lawful withdrawal, the Seller reimburses the payments required by applicable law, including the initial delivery costs to the extent that those costs must be refunded.
Where the consumer has chosen a particular method of delivery other than the least expensive standard method offered by the Seller, the business is not required to reimburse the additional costs arising solely from the choice of the more expensive service, subject to the legal conditions.
This exception does not permit a general retention of all initial shipping costs where the consumer has lawfully exercised the right of withdrawal.
The Seller must distinguish the cost of standard delivery from the additional charge associated with an optional more expensive service where that distinction is necessary for correct reimbursement.
Application of the relevant rules is assessed on the basis of the actual scope of the withdrawal, the agreed terms and the applicable national provisions.
Legal basis: Article 13(1) and (2) of Directive 2011/83/EU.
96. Available shipping countries, geographical restrictions and actual delivery capabilities
The Seller ships products to the countries and geographical areas included in the online store's actually available delivery options, taking into account the nature of the products, the capabilities of cooperating carriers and the legal restrictions applicable to the particular transaction.
Access to the website from a particular country, presentation of the online catalogue in several languages or use of a web address with the country-code extension of another state does not automatically mean that the Seller undertakes to deliver every product to any destination.
The countries and areas to which shipments are made must be presented clearly during the checkout process. Where a particular product is subject to a specific marketing or import restriction in the country of destination, the business must examine whether the particular transaction can lawfully be performed before undertaking the corresponding obligation.
The Seller may change the available delivery areas for future transactions where required by changes in actual transport services, commercial conditions or applicable legislation.
Such a change does not automatically extinguish obligations already undertaken under a binding contract. If the agreed delivery becomes impossible or is not completed within the applicable period, the Seller deals with the consequences according to the actual cause of the inability, the particular contract and the Customer's statutory rights.
Legal basis: Article 6(1)(g) and Article 18 of Directive 2011/83/EU concerning information on delivery arrangements and performance of the corresponding obligation. Articles 3 and 4 of Regulation (EU) 2018/302, where applicable, concerning geographical restrictions on access and general conditions of access.
97. Prohibited destinations and impermissible forms of delivery
The Seller does not undertake to perform a transaction where the sale, shipment or importation of the particular goods to the selected destination is prohibited by a binding provision applicable to the actual transaction.
The business must examine restrictions connected with the nature of the product, the destination country, the shipping method and the conditions for lawful making available, without assuming that a general restriction automatically applies to every related item.
Where a particular country is not included among the delivery areas actually available, the Customer must be appropriately informed and must not be led through an ordering process that creates the false impression that shipment will be carried out without qualification.
If, after conclusion of the contract, a lawful obstacle arises that makes performance of the agreed delivery impossible, the Seller examines the actual cause of the impossibility and the obligations arising from the particular contract.
The business may not automatically pass every financial consequence of non-performance on to the Customer, especially where the problem is connected with failure to provide required information or a breach of obligation by the Seller itself.
A private agreement between Seller and Customer does not permit circumvention of binding import, export or marketing restrictions.
Legal basis: Articles 6 and 18 of Directive 2011/83/EU, together with the specific marketing and import provisions applicable to the particular product and destination country.
98. Preservation of mandatory consumer rights irrespective of the commercial returns policy
The commercial returns policy applied by the online store may include additional services or more favourable service terms without restricting rights that are mandatorily provided by applicable law.
The Seller may, as applicable, offer a longer return period, an optional product exchange or another additional commercial benefit in accordance with the published terms of the particular service.
The existence of an additional commercial option does not alter the independent application of statutory withdrawal rights and rights arising from lack of conformity.
In particular, expiry of an optional commercial returns period does not automatically mean that the consumer loses rights that continue to apply under the Seller's statutory liability.
The business may not use general terms providing for no refunds, refusal of opened products or compulsory replacement with another item in order to exclude statutory remedies that must be provided.
Legal basis: Article 25 of Directive 2011/83/EU and Article 21 of Directive (EU) 2019/771 concerning the mandatory nature of consumer rights.
99. Legal equivalence and handling discrepancies between translations
Translations of the General Terms and Conditions, product descriptions and other contractual information are intended to provide substantially equivalent information to Customers using different language versions of the online store.
The Seller makes reasonable efforts to ensure that translations accurately convey the content of the corresponding contractual provisions without altering rights, obligations, time limits or conditions provided for by applicable law.
Where a material discrepancy is identified between two language versions, the business examines the content communicated to the Customer in the particular transaction, the circumstances in which the contract was concluded and the applicable rules for interpreting contractual terms.
The existence of different wording in another language does not give the Seller a general right retrospectively to select the version that most restricts its obligations or the Customer's rights.
Where applicable law provides specific interpretative rules in favour of the consumer, those rules continue to apply irrespective of the language in which the terms were originally drafted.
The Seller may maintain records of different language versions, publication dates and amendments so that the content in force when a particular contract was concluded can be verified.
Legal basis: Articles 3, 5 and 6 of Directive 93/13/EEC. In particular, Article 5 provides that, in the event of doubt as to the meaning of a contractual term, the interpretation most favourable to the consumer applies, subject to the conditions of that Article.
100. Informing visitors when communicating with an automated artificial-intelligence assistant
Where the online store uses an artificial-intelligence system for automated communication with visitors or Customers, the business must assess and apply the transparency requirements laid down by applicable law.
Where Article 50(1) of Regulation (EU) 2024/1689 applies, natural persons must be informed that they are interacting with an artificial-intelligence system unless this is obvious from the circumstances and the context of use.
The automated assistant may provide information concerning products, orders, available services and the store's communication procedures.
The business must avoid misleading presentation of the system as a human representative where applicable law requires different information to be provided.
Use of an automated assistant does not release the Seller from its contractual obligations and does not permit the creation of misleading information concerning products or the Customer's rights.
Legal basis: Article 50(1) of Regulation (EU) 2024/1689 (AI Act). The corresponding transparency obligations apply from 2 August 2026, subject to the specific and transitional provisions provided for. Shaping Europe’s digital future
101. Separation of product categories and application of specific regulatory provisions
Products presented in the online catalogue may belong to different commercial and regulatory categories that are not automatically subject to a single legal regime in relation to their production, making available, sale, advertising, importation or cross-border shipment.
The Seller must take account of the specific nature and actual characteristics of each product so that its commercial distribution is carried out in accordance with the provisions applicable to the relevant category.
The inclusion of products in the same commercial catalogue or the same general category of the online store does not mean that all products are treated in the same manner by law.
In particular, rolling papers, filters, paper tips, tubes, other accessories, tobacco products and vaping products must be assessed separately, taking into account their actual classification and the specific provisions applicable in the relevant market.
The business may not assume that the lawful marketing of a product in Greece automatically means that it may lawfully be offered at a distance in every other country of the European Union or in a third country.
Where a particular category of goods is subject to specific requirements, the store's general terms apply on a supplementary basis and do not replace the corresponding mandatory provisions.
Legal basis: Article 2 of Directive 2014/40/EU concerning definitions of products falling within its scope and Article 18 of the same Directive concerning cross-border distance sales of tobacco products. Articles 2, 4 and 5 of Regulation (EU) 2023/988 to the extent that the general product-safety regime applies.
102. Manufacturer details, responsible economic operator and safety information
The Seller ensures that the products it offers for sale are accompanied by the identification, origin and safety information required by the applicable regulatory framework for the particular category of goods.
Where a product falls within the scope of Regulation (EU) 2023/988 on general product safety, its online offer must include the information required by Article 19 of that Regulation.
Such information includes, where applicable, the prescribed identification and contact details of the manufacturer, the details of the responsible person where the manufacturer is not established in the European Union, product-identification information and the required warnings or safety information.
The Seller ensures that the information presented in the online store corresponds to the actual product details and does not arbitrarily attribute the status of manufacturer, importer or responsible economic operator to a person that does not in fact hold that status.
Where the required information is unavailable or a material doubt arises concerning the identity of the product and the lawfulness of making it available, the business must examine the matter before continuing the corresponding commercial activity.
Entrusting the supply, storage or dispatch of the product to a third-party partner does not release the Seller from the obligations imposed on it by reason of its actual role in the distribution chain.
Legal basis: Articles 9 and 19 of Regulation (EU) 2023/988 concerning manufacturers' obligations and the information that must appear in distance offers of products. These requirements apply according to the scope of the Regulation and any specific regulatory framework applicable to the product.
103. Illustrative photographs, illustrations and packaging variations
In particular cases, the online store may use illustrative photographs, illustrations or other visual material for the general presentation of a product category, a commercial product family or a range of goods available in several versions.
Where the photographic material does not accurately depict the specific version offered for sale, the Seller must ensure that the presentation does not create an incorrect impression of the material characteristics of the product to be delivered.
Use of an illustrative image must be distinguished from a case in which the photograph is presented as depicting the specific item ordered. This distinction is especially important where different versions of the same product exist in terms of size, packaging, quantity or composition.
If the manufacturer has changed the external appearance of the packaging without changing the material characteristics of the product, the Seller may update the presentation of the relevant goods according to the factual information available.
A change in packaging may not be used as a general justification for delivering a different type, a different quantity or another product that does not conform to the agreement.
Where the Customer receives a product whose appearance differs from that presented at the time of purchase and claims that the difference affects the agreed transaction, the Seller examines the incident, the actual characteristics of the goods and the information disclosed before the order.
Legal basis: Articles 6 and 7 of Directive (EU) 2019/771 concerning the description and conformity of goods; Articles 6 and 7 of Directive 2005/29/EC concerning misleading presentation or omission of material information.
104. Lawful withholding of reimbursement pending receipt of returned goods
In contracts for the sale of goods in which the consumer has lawfully exercised the right of withdrawal, the Seller may wait until receipt of the returned goods or until evidence of their dispatch is provided, whichever occurs first.
This possibility applies only in the cases and subject to the conditions prescribed by law.
Where the consumer has provided appropriate evidence that the goods were dispatched in time, the Seller may not generally rely on the absence of physical receipt as a reason for indefinitely delaying reimbursement where the relevant obligation under Article 13 applies.
If the Seller has offered to collect the goods itself, the specific exception to the possibility of withholding reimbursement is considered.
The existence of an internal procedure for inspecting the returned product does not create an independent right to extend statutory time limits beyond the cases permitted.
Any potential claim for proven diminution in the value of the goods is dealt with in accordance with the specific conditions of Article 14 and does not justify arbitrary suspension of the entire reimbursement due.
Legal basis: Article 13(3) and Article 14(2) of Directive 2011/83/EU.
105. Sealed hygiene goods and specific exceptions to the right of withdrawal
Application of an exception to the right of withdrawal for health-protection or hygiene reasons requires the specific conditions laid down by the applicable legislation to be satisfied.
The exception concerns sealed goods that are not suitable for return due to health protection or hygiene reasons and have been unsealed after delivery.
The mere commercial classification of a product as an item for personal use is not, by itself, sufficient for the exception to apply.
For products such as rolling papers, filters, paper tips and other related goods, the business must examine the actual nature of the particular product, the nature of the seal and whether the statutory conditions for the exception are objectively satisfied.
The Seller may not arbitrarily characterise every commercial package as a hygiene seal where the particular presentation does not correspond to the actual function of the packaging and the requirements of the legislation.
Where a particular exception lawfully applies, the consumer must have received the required prior information concerning the absence of the right of withdrawal or the circumstances in which that right is lost.
Application of the exception does not exclude the consumer's separate rights in the event of a defective product or another lack of conformity.
Legal basis: Article 6(1)(k) and Article 16(e) of Directive 2011/83/EU.
106. Adding a product to the electronic cart and temporary retention of selections
Adding a particular product to the electronic cart is a technical stage of the purchasing process that allows the Customer to collect, review and modify the products they wish to order.
Adding a product to the cart does not, by itself, complete the transaction or automatically create a binding sales contract between the Customer and the Seller.
Unless expressly provided otherwise by the actual operation of the store or by a specific agreement, adding a product to the cart does not mean that a particular quantity of stock has been reserved exclusively for the particular Customer.
The business may use appropriate technical mechanisms for temporarily retaining cart contents, managing the relevant session and facilitating completion of the order, in accordance with applicable personal-data-protection requirements and rules on technologies for storing information.
If the availability or commercial price of a particular product changes before the contract is concluded, the business ensures that the Customer is appropriately informed before undertaking a binding obligation to pay.
Temporary storage of products in the cart does not give the Seller the right to impose charges without the Customer's required agreement or to treat simple abandonment of the cart as acceptance of the purchase.
Legal basis: Articles 6 and 8 of Directive 2011/83/EU concerning prior information and the process for undertaking an obligation to pay; Articles 10 and 11 of Directive 2000/31/EC concerning the electronic ordering process.
107. Personalised pricing and automated evaluation of Customers' commercial data
The Seller may apply different commercial offers or special prices to particular categories of Customers provided that the practice is permitted by the applicable legislation and its material terms are appropriately disclosed.
Where the price of a particular product is personalised on the basis of automated decision-making, the business must provide the consumer with the specific information required by law before the consumer is bound by the corresponding distance contract.
This obligation is assessed separately from ordinary dynamic pricing, under which prices change on the basis of general commercial factors such as demand or procurement costs without being personalised through automated evaluation of the particular Customer.
Where personal data are used to determine a personalised price, the Seller must have an appropriate lawful basis for processing, provide the required information and apply the principles of purpose limitation, data minimisation and transparency.
The business may not assume that general acceptance of the Terms and Conditions automatically constitutes a sufficient lawful basis for every form of profiling or automated processing of personal data.
Where automated processing leads to a decision producing legal effects concerning a natural person or similarly significantly affecting that person, application of the specific restrictions and safeguards in Article 22 of the General Data Protection Regulation must also be considered.
The business must avoid pricing practices that breach specific non-discrimination rules or use personal data contrary to the lawful conditions governing the corresponding processing.
Legal basis: Article 6(1)(ea) of Directive 2011/83/EU, as inserted by Directive (EU) 2019/2161; Articles 5, 6, 13, 14 and 22 of Regulation (EU) 2016/679 (GDPR).
108. Manifest catalogue errors, inaccurate listings and remediation procedure
The Seller may use automated product-import systems, electronic supplier integrations and central commercial-content databases to present and update its catalogue.
Despite the application of appropriate control procedures, objective technical errors may arise when a particular product is imported or updated, potentially affecting its description, photograph, quantity, price, code or another element of its commercial presentation.
Where such an error is identified, the business ensures that the relevant information is corrected so that future listings and transactions are based on the actual characteristics of the goods.
If the error has affected an order already submitted, the Seller examines the actual stage of the transaction, the information communicated to the Customer and the obligations undertaken under the applicable contract.
The existence of a technical error does not automatically release the Seller from every obligation to perform the transaction. Likewise, identification of an objectively obvious error may have different legal consequences depending on the actual circumstances and the provisions governing the particular contract.
The Seller may not rely on a general catalogue-error clause to alter arbitrarily the agreed quantity, price or product characteristics of a contract already concluded.
Where the inaccuracy in the commercial presentation constitutes misleading information or results in delivery of a non-conforming product, the corresponding legal rights of the Customer apply.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning misleading commercial practices; Articles 6, 7 and 13 of Directive (EU) 2019/771 concerning conformity of goods and consumer rights in the event of lack of conformity.
109. Financial documentation of transactions, retention of evidence and auditability
The Seller organises the keeping of information necessary for proper management and lawful documentation of transactions carried out through the online store.
The relevant information may include the order number, products and quantities agreed, selling price, applicable tax charges, selected payment method, payment status and corresponding lawful documents.
The business may retain necessary information concerning order performance, shipment, delivery, reimbursements and communications connected with the particular transaction to the extent that there is a lawful purpose for retaining it.
Use of such information may be necessary for fulfilling contractual and tax obligations, investigating actual payment problems, dealing with transaction disputes and establishing or supporting lawful claims.
Where data are retained for more than one purpose, the business must assess separately the lawful basis, necessity and permissible retention period for each category of information.
The Seller may not assume that the technical ability to store data automatically creates a right to retain or process them without a time limit.
Customers' personal data are protected by appropriate technical and organisational measures, while access is limited to persons and functions for which there is a genuine and lawful need.
Legal basis: Article 8(7) of Directive 2011/83/EU concerning confirmation of the contract on a durable medium; Articles 5, 6 and 32 of the GDPR concerning lawfulness, purpose limitation, retention period and security of personal data.
110. Special prices for professional transactions and wholesale sales
The Seller may offer particular commercial prices, quantity discounts, special payment terms or other commercial benefits to businesses and professionals making purchases in the course of their commercial or professional activity.
The relevant terms may differ from those applicable to ordinary consumer transactions provided that they correspond to the actual nature of the purchase and are agreed in accordance with applicable law.
The business may set special prices for particular quantities, recurring orders, long-term cooperation or other objective commercial circumstances.
Where a professional transaction is governed by a particular commercial agreement, the material terms concerning price, quantity, payment and delivery must be appropriately determined before the corresponding binding obligations are undertaken.
The mere entry of professional details or issuance of an invoice is not, by itself, sufficient to exclude consumer status where the actual circumstances and applicable law require a different legal treatment.
The Seller may maintain different commercial price lists and processes for managing professional orders without unilaterally altering agreed terms of a particular contract.
Professional transactions must be dealt with on the basis of the parties' actual status and the rules applicable to the particular commercial relationship.
Legal basis: Article 2(1) of Directive 2011/83/EU concerning the definition of a consumer and Article 2(2) concerning the definition of a trader. Specific terms of genuine B2B transactions are additionally governed by the applicable national contract and commercial law.
111. Import restrictions and obligations for shipments outside the European Union
Shipment of goods to a country outside the European Union may be subject to customs, tax, administrative or other specific requirements depending on the nature of the product, country of origin, destination and actual terms of the transaction.
Before undertaking a particular delivery obligation, the Seller must examine whether the product can lawfully be shipped to and imported into the relevant destination on the basis of the information and obligations applicable to the particular case.
Where the Customer may incur additional import duties, taxes or other mandatory charges, the required pre-contractual information concerning the existence and allocation of those charges must be provided.
The Seller may not generally and retrospectively pass on to the Customer every additional cost or consequence arising from inadequate information, incorrect shipping details or breach of an obligation resting on the business itself.
In B2B transactions, more specific terms concerning customs clearance, transport costs, import duties and allocation of particular risks may be agreed provided that those agreements are lawful and sufficiently clear.
If importation of a particular product is prohibited in the country of destination, the existence of a private agreement between the parties does not automatically make that import lawful.
Legal basis: Regulation (EU) No 952/2013 establishing the Union Customs Code and Article 6(1)(e) of Directive 2011/83/EU concerning the required prior information on the total price and additional charges.
112. Different commercial prices between online stores
The Seller may apply different commercial pricing policies in the online stores it operates or in different distribution channels in accordance with actual commercial conditions and applicable legal obligations.
The existence of common technical infrastructure, common suppliers or the same products in several online stores does not automatically create an obligation to apply identical commercial prices to all transactions.
Different prices may be connected with objective factors such as different commercial agreements, actual distribution costs, service costs, available delivery services or other lawful commercial parameters.
Application of different prices must comply with provisions concerning transparency, consumer protection and restrictions on unjustified discrimination that may apply to the particular transaction.
The Customer is informed of the actual price applicable in the store through which the purchase is made and of the total price before final submission of the order.
Subsequent discovery that the same product is offered at a different price by another store does not automatically alter the agreed price of the particular transaction, without prejudice to any applicable mandatory provisions.
The business must avoid misleading comparisons between different stores, particularly where the relevant offers do not concern genuinely identical products, quantities or delivery terms.
Legal basis: Articles 3 and 4 of Regulation (EU) 2018/302, where applicable, concerning access to online interfaces and general conditions of access to goods or services; Articles 6 and 7 of Directive 2005/29/EC concerning misleading commercial information.
113. Professional transactions, B2B invoicing and identification of the buyer's tax details
Where a particular order is placed by a business or professional in the course of their actual commercial or professional activity, the Seller issues the corresponding tax document according to the nature of the transaction and the applicable provisions.
For correct issuance of the document, it may be necessary to provide the buyer's legal company name or professional details, tax identification number, address and other information required by law.
The Customer must provide accurate details for issuance of the relevant document and appropriately communicate any necessary corrections in accordance with the actual transaction.
Where the sale is between businesses established in different Member States of the European Union, the Seller examines the buyer's tax status, the actual movement of the goods and the conditions for applying the corresponding VAT regime.
The inclusion of a foreign tax-identification number does not automatically result in exemption of the transaction from VAT or application of a particular cross-border tax regime.
The business may carry out the necessary lawful checks of the tax information supplied for invoicing to the extent required for proper fulfilment of its tax obligations.
Where the particular transaction falls within the prescribed cases of exemption or special tax treatment, the Seller applies the corresponding rules and retains the required evidence.
The buyer's actual professional status and the purpose of the transaction are assessed separately from the process of issuing a tax document. The mere issuance of an invoice is not, by itself, sufficient to exclude mandatory consumer rights where those rights apply according to the actual substance of the transaction.
Legal basis: Articles 138, 220 and 226 of Directive 2006/112/EC concerning the conditions for exemption of intra-Community supplies, the issuing of invoices and their required particulars. Tax treatment must be determined on the basis of the actual transaction and the relevant national provisions.
114. Partial performance of a large professional order and agreement on split delivery
Where a particular professional order includes a large quantity of goods and there is an actual inability to make the entire agreed quantity immediately available, the Seller may propose partial performance of the transaction to the professional buyer.
The relevant agreement may include the quantity to be delivered immediately, subsequent delivery of the remaining goods, the corresponding performance times and the financial consequences of the particular modification.
A proposal for partial performance does not automatically mean that the professional buyer is required to accept terms different from those already agreed.
The Seller must distinguish between a case in which split delivery was provided for in the original agreement and a case involving a subsequent modification of the contract.
The inability of a particular supplier to perform does not automatically alter the Seller's liability towards the professional buyer.
Legal basis: Applicable national contract law and, for international sales contracts to which it applies, Articles 33, 49 and 73 of the United Nations Convention on Contracts for the International Sale of Goods (CISG). Application of the CISG must be assessed transaction by transaction.
115. Display of prices and information concerning the actual price
The prices of products displayed in the online catalogue must be presented clearly so that the Customer can know the actual price of the particular unit of sale before submitting the order.
For consumer transactions, prices are presented in accordance with the applicable requirements concerning the final selling price, tax charges and the other information required for proper information of the buyer.
Where a product is offered in more than one quantity or in different packaging, the displayed price must be clearly linked to the particular quantity or commercial unit selected by the Customer.
The business may present special multipack prices, quantity discounts or different commercial options, provided that the corresponding presentation does not create a misleading impression regarding the actual value or quantity of the product.
The Seller must avoid displaying additional undisclosed mandatory charges at a later stage of the transaction in breach of the applicable prior-information requirements.
The price agreed under a binding contract is not changed unilaterally by a subsequent amendment to the commercial catalogue unless such a change is lawfully permitted under the terms of the particular transaction.
Legal basis: Articles 3 and 4 of Directive 98/6/EC concerning the indication of prices and Article 6(1)(e) of Directive 2011/83/EU concerning the total price and additional charges.
116. Limits on the functions of an automated assistant and avoidance of unauthorised commercial commitments
The online store's automated assistant may be used to provide information, facilitate communication and support the available customer-service processes.
The business defines the actual functions the system is permitted to perform and the cases in which intervention by an authorised representative of the Seller is required.
The assistant must not present offers, discounts, reimbursements or other changes to contractual terms as approved commercial agreements where it does not have actual authority to make them.
This provision does not automatically release the Seller from responsibility for statements or actions of an automated system used by the Seller in the course of its commercial activity.
If the assistant provides inaccurate material information or creates an actual dispute concerning a particular transaction, the Seller examines the matter in accordance with the applicable contractual obligations and consumer-protection rules.
The business may organise procedures for human review, correction of information and restriction of system functions where actual problems are identified.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning misleading commercial practices and Articles 6 and 8 of Directive 2011/83/EU concerning pre-contractual information and conclusion of distance contracts. The internal allocation of the assistant's authorisations is an organisational process of the business.
117. Lack of conformity of the delivered product with the agreement
The Seller is required to deliver to the Customer goods that correspond to the characteristics and terms of the particular sales contract, as well as to the objective conformity requirements laid down by the applicable legislation.
Conformity is assessed, among other things, by reference to the description, type, quantity, quality, functionality, compatibility, fitness for the agreed or ordinary purpose of use and the other characteristics forming an essential part of the transaction.
Delivery of a different version, a smaller quantity or goods with materially different characteristics from those agreed may constitute a lack of conformity, even where the goods delivered belong to the same brand or product family.
Where the Customer claims that the delivered product does not conform to the agreement, the Seller examines the matter on the basis of the order details, the commercial description, the actual condition of the goods and any other relevant evidence.
The business may not generally exclude its liability by arguing that the information originated from a supplier or that shipment was performed by an independent partner, where the relevant obligation rests with the Seller under the law.
Where a lack of conformity is established, the corresponding statutory remedies apply subject to the conditions applicable to the particular case. The mere existence of an internal inspection procedure or commercial returns policy does not restrict the consumer's mandatory rights.
Legal basis: Articles 5–8 of Directive (EU) 2019/771 concerning conformity requirements for goods, Article 10 concerning the seller's liability, and Articles 13–16 concerning remedies, price reduction and termination of the contract.
118. Bank fees, payment-service charges and restrictions on passing costs on to the Customer
The Seller may use the services of banks, financial institutions and other licensed providers for accepting and processing the financial transactions of the online store.
Those providers may charge the business payment-processing commissions, settlement costs or other contractual charges in accordance with the actual services they provide.
The existence of such charges does not automatically mean that the Seller is entitled to pass them on to the consumer as an additional charge for using a particular means of payment.
For payment instruments covered by the prohibition on surcharges, the business must comply with the corresponding specific restrictions regardless of the actual amount of the fee it pays to its provider.
Where imposition of a particular charge is permitted under the applicable legislation, the requirements concerning its permissible amount and prior disclosure to the Customer must be observed.
The business may not use a general term concerning bank charges as a basis for imposing unspecified or undisclosed financial charges after conclusion of the contract.
Where the Customer makes payment through a bank account or financial institution that applies independent charges for its own services, allocation of the relevant costs is assessed under the applicable payment-services framework and the actual terms of the transaction.
In the event of a lawful withdrawal, the Seller may not deduct from the refund due any impermissible refund fee or other administrative charge.
The business must organise its commercial pricing and payment process in a manner that distinguishes actual business costs from charges that may lawfully be imposed on the Customer.
Legal basis: Article 19 of Directive 2011/83/EU concerning charges for the use of means of payment and Article 62(3)–(5) of Directive (EU) 2015/2366, which includes a specific prohibition on surcharges for certain regulated payment instruments and services. Article 13(1) of Directive 2011/83/EU concerning reimbursement without the consumer incurring fees as a result of the means of reimbursement.
119. Delivery of the goods to the Customer and completion of the contractual obligation
Delivery of the goods is carried out in the agreed manner, at the intended place and under the conditions applicable to the particular transaction.
The Seller must perform the contract by delivering the goods to the consumer or to a person lawfully designated as recipient in accordance with the applicable provisions.
Physical handing of the products to the carrier does not automatically amount to delivery to the consumer.
Where the carrier has been selected from among the services offered by the Seller, the risk of loss of or damage to the goods is, as a rule, transferred when the consumer or a third person designated by the consumer, other than the carrier, acquires physical possession of them.
Actual delivery is assessed on the basis of the available evidence and the circumstances of the particular shipment.
An electronic indication that an order has been completed does not automatically extinguish the Customer's right to dispute actual receipt of the goods.
After delivery, the legal rights arising from withdrawal, lack of conformity and other mandatory provisions governing the particular contract continue to apply.
Legal basis: Articles 18 and 20 of Directive 2011/83/EU.
120. Temporary quarantine of a problematic batch and prevention of further supply of dangerous products
Where reliable information arises that a particular batch of products may present a risk to consumers' health or safety, the Seller must examine the need to take appropriate measures concerning that batch.
Measures may include suspension of new sales, quarantine of available stock, identification of affected products and cooperation with the manufacturer, importer or competent authorities.
The extent of the action must be determined on the basis of the actual risk information and the applicable obligations of the particular economic operator.
The existence of a problem in a particular batch does not automatically mean that all products of the same brand present the same risk.
Likewise, the absence of a confirmed incident of harm does not justify continued supply of a dangerous good where the statutory conditions require particular measures to be taken.
The Seller must cooperate with the competent authorities and fulfil the prescribed information, withdrawal or recall obligations in accordance with the Seller's actual role.
Legal basis: Articles 9, 11 and 12 of Regulation (EU) 2023/988 concerning the obligations of manufacturers, importers and distributors.
121. Selection of payment method and disclosure of available financial procedures
The Customer may choose the method of payment for the order from the methods actually available and offered by the online store for the particular transaction.
The available options may include, as applicable, card payment, bank transfer or other lawful payment services, according to the actual technical and commercial operation of the store.
The Seller must inform the Customer of the accepted payment methods and the material conditions for completing the corresponding financial transaction before final submission of the order.
Where the selected payment method requires an additional authentication, confirmation or authorisation procedure by an independent payment-service provider, the transaction is completed in accordance with the corresponding legal and technical rules.
The business may not impose arbitrary additional charges for the use of a particular payment method in breach of the specific restrictions applicable to the relevant instrument.
The possibility of applying different payment methods to particular transactions must be assessed in accordance with applicable law, including rules prohibiting specific forms of unjustified discrimination between buyers.
The Seller retains the ability to verify actual completion or confirmation of payment before fulfilling the order where this is provided for by the agreement and applicable provisions.
Legal basis: Article 8(3) and Article 19 of Directive 2011/83/EU concerning information on accepted means of payment and related charges; Article 5 of Regulation (EU) 2018/302 concerning the prohibition of certain discrimination in payments; Article 97 of Directive (EU) 2015/2366 concerning strong customer authentication.
122. Contractual supplier warranties concerning product lawfulness and third-party rights
In commercial agreements with suppliers, the Seller may seek specific representations and contractual warranties concerning the authenticity of products, their lawful origin and rights to use the commercial material supplied.
The relevant agreements may define the supplier's obligations concerning provision of accurate product information, availability of required safety information and notification of any non-compliance incidents.
The Seller may agree lawful consequences in the event of breach of those obligations, including the possibility of seeking compensation for actual loss where the prescribed conditions are met.
The existence of a contractual supplier warranty does not automatically release the Seller from independent obligations imposed directly on it towards consumers or competent authorities.
The supplier's obligations and the Seller's lawful rights against the supplier must be distinguished from the contractual relationship with the final buyer.
Legal basis: Article 18 of Directive (EU) 2019/771 concerning the seller's right of redress and Articles 9–12 of Regulation (EU) 2023/988 concerning the respective obligations of economic operators.
123. Quantity discounts and commercial presentation of multipacks
The Seller may apply different prices depending on the quantity of products selected by the Customer, provided that the corresponding commercial presentation is permitted for the particular category of goods.
Quantity discounts may concern individual products, multipacks, commercial boxes or other lawful units of sale, provided that the Customer can identify the actual quantity and total price of the particular option.
Where a product is available in several pack sizes containing different numbers of units, the price must be clearly linked to the particular commercial unit and must not create a misleading impression concerning the contents of the package.
The business may present the comparative economic difference between individual options provided that the corresponding calculations reflect the actual prices and quantities.
Application of a quantity discount does not give the Seller the right to deliver a smaller quantity or different products from those agreed.
Where the order includes several units of the same goods, the Seller must perform the contract in accordance with the actual quantity agreed, without prejudice to any lawful subsequent amendment to the transaction.
Legal basis: Articles 3 and 4 of Directive 98/6/EC concerning indication of prices; Articles 6 and 7 of Directive (EU) 2019/771 concerning quantity and agreed characteristics of goods.
124. Inability to complete customs clearance due to omission of information by the professional buyer
In international B2B transactions, the Seller and the buyer may determine by specific agreement the obligations to provide documents, tax information and other details required for lawful customs clearance of the goods.
Where the obligation to provide particular information lawfully and contractually rests on the buyer, the consequences of failing to fulfil it are assessed in accordance with the particular agreement and applicable law.
The Seller may request the necessary documents before shipment where they are required for lawful performance of the transaction.
The buyer's omission does not automatically release the Seller from independent obligations resting on the Seller under customs or other applicable legislation.
Any claim for additional costs or actual loss must be based on the particular contractual obligations and actual circumstances.
Legal basis: Articles 15 and 77 of Regulation (EU) No 952/2013 together with the contract law applicable to the professional transaction.
125. Preservation of the mandatory rights of the contracting parties
No provision of these General Terms and Conditions is intended to exclude or restrict a right mandatorily granted to the Customer by applicable law.
Contractual provisions concerning orders, payments, delivery, withdrawal, the Seller's statutory liability, conformity of goods and dispute resolution apply subject to the mandatory rules governing the particular transaction.
Acceptance of these terms does not constitute a waiver of rights that cannot be excluded by private agreement and does not release the Seller from obligations imposed by mandatory provisions.
In cross-border consumer transactions, any choice of a particular applicable law does not deprive the consumer of the protection of mandatory provisions that would apply under the relevant rules of private international law.
The Seller likewise retains its lawful rights to address unjustified claims, malicious acts and breaches of contractual obligations, without creating a general presumption of liability or exemption for any contracting party.
Legal basis: Article 25 of Directive 2011/83/EU, Article 6 of Directive 93/13/EEC and Article 6(2) of Regulation (EC) No 593/2008 (Rome I) concerning mandatory consumer protection in cross-border contracts.
126. Customs classification, description of goods and correct shipment documentation
Products shipped in the context of international commercial transactions must be described in the relevant commercial and customs documents in accordance with their actual nature, characteristics and the requirements applicable to the particular shipment.
The Seller or competent economic operator ensures, within the scope of its legal obligations, correct customs classification of the goods and provision of the information required for their lawful export or import.
The trade name used in the online catalogue does not necessarily replace the required customs description or official tariff classification of the particular product.
The business may not use an inaccurate description, incorrect quantity, misleading declared value or other false information for the purpose of avoiding customs obligations or specific import restrictions.
Where shipment is carried out by a third-party supplier or partner, the actual obligations of each economic operator involved must be determined in accordance with the contract and applicable provisions.
If an error is identified in customs information or an accompanying document, the business examines the prescribed correction procedures and the consequences that may arise for the corresponding transaction.
Legal basis: Regulation (EU) No 952/2013, in particular Articles 15 and 162 concerning information provided to customs authorities and particulars of the customs declaration.
127. Opening external packaging and distinction from substantive use of the product
Opening the external packaging of a product does not automatically mean that the consumer loses the statutory right of withdrawal.
The possibility of examining the goods must be assessed according to their nature, characteristics and the ordinary manner in which the consumer could examine a comparable product before purchase.
The Seller may distinguish the simple opening of external wrapping from actual consumption, use or alteration of the goods contained within it where that distinction is material to application of the statutory provisions.
The existence of protective packaging, commercial wrapping or other packaging material does not automatically mean that the particular product falls within a specific exception to the right of withdrawal.
Where unsealing a particular good may affect its returnability for genuine health-protection or hygiene reasons, application of the relevant exception is assessed separately in accordance with the statutory conditions.
The Seller may not use a general statement prohibiting returns of opened packages in order to exclude withdrawal rights mandatorily granted to the consumer.
Legal basis: Articles 9, 14(2) and 16(e) of Directive 2011/83/EU.
128. Automated pricing, commercial algorithms and control of financial data
The Seller may use information systems, automated algorithms and other technical processes to calculate, monitor and adjust the commercial prices of products made available through the online store.
Such mechanisms may take into account objective commercial parameters, such as actual procurement cost, tax charges, transport costs, available quantity, changes in supplier price lists and other lawful factors connected with the particular commercial activity.
Use of an automated pricing system does not release the Seller from the obligation to present prices correctly, comply with agreed contractual terms and avoid misleading commercial practices.
The business organises appropriate procedures for checking the data used by automated mechanisms so as to reduce the risk of publishing inaccurate prices due to incorrect supplier information, erroneous product matching, technical malfunction or another objective error.
Where a product is offered through more than one online store, use of a common central pricing system may be combined with different commercial policies for each store, provided that the corresponding practices are lawful and do not breach applicable competition or non-discrimination rules.
Automated calculation of a new price does not automatically create a right to alter the price of a contract already concluded. New prices apply to future transactions in accordance with the lawful process for concluding them.
Where the automated mechanism uses personal data or profiles of particular Customers to determine personalised prices, the relevant transparency and data-protection requirements also apply.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning the avoidance of misleading commercial practices; Article 6(1)(e) and (ea) of Directive 2011/83/EU concerning the total price and information on personalised pricing based on automated decision-making.
129. Inspection of the condition of returned products and liability for proven diminution in value
Where the consumer returns goods in the context of a lawful withdrawal, the Seller may examine the actual condition of the product and determine whether handling has taken place beyond what is necessary to establish the nature, characteristics and functioning of the goods.
The examination must be carried out by reference to the actual characteristics of the particular goods and the conditions applicable to lawful withdrawal.
The consumer is not automatically liable for any alteration to the external packaging and is not generally required to return every product in absolutely unopened or pristine packaging regardless of the nature of the goods and the applicable provisions.
Where handling beyond what is necessary for the ordinary examination of the product is established, the consumer may be liable for the corresponding diminution in value, provided that the legal conditions are met.
The business must assess the actual cause and extent of the diminution in value and avoid imposing arbitrary or predetermined deductions that are unrelated to actual loss.
The Seller may not assume that any testing or simple inspection of a product automatically results in the loss of the entire right of withdrawal.
Application of the specific exception for sealed goods that are not suitable for return due to health protection or hygiene reasons requires a separate assessment of the conditions in Article 16(e) of Directive 2011/83/EU.
The business may not assume that all rolling papers, filters, paper tips and other related products are automatically excluded from the right of withdrawal solely because of the general commercial category to which they belong.
In addition, where the Seller has failed to provide the required information concerning the right of withdrawal, the specific consequences provided for in relation to the consumer's liability for diminution in value apply.
Legal basis: Article 14(2) and Article 16(e) of Directive 2011/83/EU. The conditions governing the exception for sealed goods are also discussed in the European Commission's interpretative guidance on the application of Directive 2011/83/EU.
130. Orders containing several goods, separate deliveries and calculation of the withdrawal period
Where the consumer orders several goods under one contract and those goods are delivered separately, the withdrawal period is calculated in accordance with the specific provisions applicable to that form of delivery.
Where several goods have been ordered in one order and are delivered separately, the period begins on the day on which the consumer, or a third party designated by the consumer other than the carrier, acquires physical possession of the last good.
Where delivery of a particular good takes place in several lots or pieces, the corresponding rules concerning receipt of the last lot or last piece apply.
The Seller may not apply a general calculation from the date of the first shipment where the applicable legislation provides that the starting point is receipt of the last good.
The business may retain the necessary information concerning the individual deliveries in order to determine correctly when the relevant period begins.
Partial delivery must not be used for the purpose of artificially restricting the consumer's rights.
Where the goods were acquired under separate contracts, application of the relevant periods is assessed on the basis of the actual content of each contract.
Legal basis: Article 9(2)(b) of Directive 2011/83/EU.
131. Discontinuation of a product and modification of the commercial catalogue
The Seller retains the ability to modify the online catalogue, add new categories of goods, discontinue the future offering of particular products or temporarily suspend the possibility of placing new orders where this is required for genuine commercial, technical, organisational or lawful reasons.
Discontinuation may be connected, by way of example, with exhaustion of stock, cessation of production, termination of a commercial relationship, a change in the regulatory framework, a product recall or a documented problem concerning the safety or lawfulness of marketing the product.
A decision no longer to offer a product for future purchases does not automatically release the Seller from obligations already undertaken under a binding sales contract.
Where there is a pending order for a product whose availability is being discontinued, the business examines the particular transaction on the basis of the actual facts, applicable legal obligations and the buyer's rights.
The Seller may propose an alternative product, a different version or a modification of the order. Acceptance of the proposal takes place in accordance with the rules governing modification of the particular contract and is not presumed merely because the originally ordered goods can no longer be supplied.
If the order cannot be performed lawfully or in accordance with the contract, the prescribed consequences apply, including reimbursement of amounts due to the Customer where the relevant conditions are met.
Legal basis: Article 18 of Directive 2011/83/EU, Articles 5–7 and 13 of Directive (EU) 2019/771, and Articles 5 and 9 of Regulation (EU) 2023/988 to the extent that discontinuation is connected with product-safety obligations.
132. Combined application of offers and different commercial benefits
The Seller may determine the conditions under which different lawful commercial offers, quantity discounts, coupons or loyalty programmes may be combined in the same transaction.
The possibility of combining different promotional activities must be specified in a way that enables the Customer, before completing the purchase, to know whether more than one commercial benefit may be used.
Where a particular offer cannot be combined with another, the relevant restriction must be appropriately disclosed and must not appear for the first time after a binding obligation to pay has been undertaken.
The business may use automated mechanisms to calculate applicable discounts, provided that the final result corresponds to the agreed terms and does not create a misleading impression concerning the total amount of the order.
Where several discounts are applied successively, the Seller ensures that the method used to calculate them corresponds to the terms of the offer and does not inaccurately present the total financial benefit.
Any technical error in combining different promotional activities is assessed according to the actual stage of the transaction and the applicable contractual provisions.
The Seller may not use the terms governing combinations of offers as a general basis for imposing additional undisclosed charges or unilaterally altering a price already agreed.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC and Articles 6 and 8 of Directive 2011/83/EU concerning information on the material financial terms of a distance transaction.
133. Transfer of the risk of loss or damage to goods
The risk of loss or damage to goods shipped to the consumer passes in accordance with the specific provisions applicable to the particular contract.
Where the Seller sends the products to the consumer through a carrier included among the delivery options offered, the risk generally passes when the consumer, or a third party designated by the consumer other than the carrier, acquires physical possession of the goods.
Handing the parcel by the Seller to the transport company does not automatically transfer the risk to the consumer.
If the consumer has independently commissioned transport from a carrier that was not included among the options offered by the Seller, the risk may pass upon delivery of the goods to that carrier subject to the conditions in Article 20 of Directive 2011/83/EU.
Transfer of the risk of loss or damage does not extinguish the Customer's statutory rights in the event of a lack of conformity of the goods.
The Seller may not use a general contractual clause to transfer the risk to the consumer at an earlier stage than permitted by the applicable law.
For genuine B2B transactions, different lawful contractual arrangements may apply and must be determined in accordance with the particular commercial relationship.
Legal basis: Article 20 of Directive 2011/83/EU.
134. Payment by bank transfer and verification of actual payment
Where the online store offers payment by bank transfer, the Customer is informed of the necessary payment details, the amount payable and the material conditions applicable to that payment method.
The business may provide specific bank-account details and an appropriate order identifier so that the transfer can be correctly matched to the corresponding commercial transaction.
The Customer must use the payment details lawfully communicated by the Seller and pay the amount corresponding to the particular agreed transaction.
Sending a bank-transfer instruction does not automatically amount to final crediting of the amount to the Seller's account. The actual payment status is assessed on the basis of available banking information and the applicable rules governing execution of the corresponding service.
Where lawfully agreed, the Seller may proceed with performance of the order after appropriate confirmation of payment. This process does not permit arbitrary extension of agreed deadlines or imposition of additional charges not provided for by the contract or law.
If the Customer pays an incorrect amount or uses an inaccurate payment reference, the business examines the actual transaction data and cooperates with the Customer to identify the payment correctly.
Where it is established that a particular amount was paid without a legal or contractual basis, the business deals with its reimbursement in accordance with the applicable provisions and the actual reason for the payment.
Legal basis: Articles 64 and 87 of Directive (EU) 2015/2366 concerning authorisation of payment transactions and availability of funds to the payee. Articles 6 and 18 of Directive 2011/83/EU concerning pre-contractual information and the contractual delivery obligation.
135. Amicable settlement and alternative resolution of consumer disputes
In the event of a dispute arising from a particular transaction, the Seller and the Customer may seek an amicable settlement through direct communication and exchange of the necessary information.
An attempt at amicable settlement may concern establishing the actual facts, remedying a particular defect or considering a lawful solution appropriate to the particular contract.
The consumer retains the ability to refer to competent alternative consumer-dispute-resolution bodies in accordance with applicable provisions and the jurisdictional conditions of the relevant body.
The existence of an internal complaints procedure does not permit the Seller arbitrarily to exclude the consumer's access to lawful protection mechanisms.
Where an obligation exists to provide information concerning a particular alternative dispute-resolution body, the business must provide the corresponding information accurately.
Use of an amicable or out-of-court dispute-resolution mechanism does not automatically extinguish the right to judicial protection.
Legal basis: Directive 2013/11/EU on alternative dispute resolution for consumer disputes and the corresponding applicable national provisions.
The former European ODR platform was discontinued on 20 July 2025 and must no longer be presented as an active complaints-submission mechanism.
136. Repair of a non-conforming product and obligation to provide an effective remedy
Where a particular good shows a lack of conformity, the consumer may have a right to remedy through repair subject to the specific conditions of the applicable legislation.
The availability of repair is assessed on the basis of the nature of the product, seriousness of the lack of conformity, actual possibility of remedy and the relationship between that remedy and the available lawful alternatives.
Repair must be carried out free of charge for the consumer, within a reasonable period and without significant inconvenience, in accordance with the requirements of Article 14 of Directive (EU) 2019/771.
For goods whose nature does not make repair practically possible, the other statutory remedies are considered.
The Seller may not impose repair as the exclusive solution in every case where, in the actual circumstances, the consumer has a different statutory remedy available.
The remedy is provided without restricting rights available where the lack of conformity reappears or is not effectively remedied.
Legal basis: Articles 13 and 14 of Directive (EU) 2019/771.
137. Examination of complaints and obligation to provide an appropriate response to the Customer
The Seller ensures that complaints submitted through the available means of communication are examined and that an appropriate response is provided concerning the actual status of the particular transaction.
The examination is carried out on the basis of available order details, payment and delivery information, the actual condition of the goods and other circumstances related to the particular request.
The business may request additional clarification where necessary to establish the facts.
The examination procedure must not be used to unjustifiably delay fulfilment of obligations laid down by law.
If the complaint concerns lawful withdrawal, reimbursement or remedy for lack of conformity, the corresponding time limits and substantive obligations apply.
The Seller retains the right to reject a particular request where its legal or contractual conditions are not met, on the basis of the actual facts and without automatically characterising the Customer as acting in bad faith.
Submission of a complaint may not result in loss of the right to pursue another lawful claim.
Legal basis: Articles 13–16 of Directive (EU) 2019/771 and Articles 13–14 and 18 of Directive 2011/83/EU, depending on the nature of the particular request.
138. Language of the transaction and multilingual presentation of the online store
The online store may provide its services, present its products and make the relevant information available in more than one language in order to facilitate access and transactions by customers from different countries.
Availability of a particular language version does not automatically mean that the store undertakes to ship every product to all countries in which that language is used. The actual delivery areas, restrictions by product category and other material terms of the transaction must be appropriately disclosed to the Customer before completion of the order.
Information concerning product characteristics, the identity of the Seller, prices, payments, delivery, withdrawal rights and other material contractual obligations must be provided in a clear and comprehensible manner in accordance with the language requirements applicable to the particular transaction and country in which the product is made available.
The Seller takes steps to ensure that use of a different language does not lead to misleading presentation of the product, concealment of material information or creation of contradictory contractual obligations.
The Customer's selection of a language version does not constitute a waiver of rights granted by the applicable legislation and does not automatically amount to a choice of the law of a particular country.
Legal basis: Articles 6 and 8 of Directive 2011/83/EU concerning pre-contractual information and requirements for distance contracts; Article 5 of Directive 93/13/EEC concerning clear and intelligible drafting of contractual terms.
139. Retention of order history and documentation of contractual obligations
The Seller organises appropriate retention of information necessary to document electronic transactions, fulfil contractual and tax obligations and deal with actual incidents connected with particular orders.
Such information may include the order number, date of submission, agreed products and quantities, total price, payment status, shipping details, lawful documents and relevant communications necessary to document the transaction.
The business may retain the version of the contractual terms communicated to the Customer when the contract was concluded and the information necessary to prove the actual agreement between the parties.
Where the Customer has an electronic account, the store may provide access to the Customer's order history in accordance with actual technical capabilities and personal-data-protection requirements.
Retention of history in the Customer's account does not automatically replace the obligation to provide confirmation of the contract on a durable medium where required by the applicable legislation.
The business must apply appropriate technical and organisational measures to protect transaction data in order to reduce the risk of unauthorised access, loss, alteration or unlawful processing.
The retention period for the relevant information is determined in accordance with the actual needs for fulfilling contractual and legal obligations, applicable tax requirements and personal-data-protection principles.
The business may not assume that general acceptance of the Terms and Conditions automatically provides a lawful basis for indefinite retention of every item connected with the Customer's commercial activity.
Legal basis: Article 8(7) of Directive 2011/83/EU concerning confirmation of a distance contract on a durable medium; Articles 5, 6, 13 and 32 of Regulation (EU) 2016/679 concerning lawful processing, information, storage limitation and security of personal data.
140. Additional delivery period and right to terminate the contract
Where the Seller fails to fulfil the obligation to deliver the goods within the agreed time or the statutory period applicable to the particular contract, the consumer may, as a rule, call upon the Seller to make delivery within an additional period appropriate to the circumstances.
The additional period must be assessed by reference to the type of product, the actual cause of the delay, the circumstances of the particular transaction and the applicable obligations.
If the Seller fails to deliver even within the additional period, the consumer is entitled to terminate the contract in accordance with the specific rules of Article 18 of Directive 2011/83/EU.
An additional period is not required in every case. Where the Seller has refused to deliver the goods, where delivery within the agreed period was essential in light of the circumstances surrounding conclusion of the contract, or where the consumer informed the Seller before conclusion that delivery by a particular date was essential, the corresponding specific provisions apply.
In the event of lawful termination of the contract due to non-delivery, the Seller reimburses without undue delay all sums paid under the contract in accordance with the applicable provisions.
Legal basis: Article 18(2)–(4) of Directive 2011/83/EU.
141. Means of reimbursement and protection of the consumer against additional charges
Reimbursement following lawful exercise of the right of withdrawal is made using the same means of payment as that used for the original transaction, unless the consumer has expressly agreed otherwise.
Use of a different means of reimbursement must not result in a financial charge to the consumer because of the particular refund.
The Seller may use the available functions of the original payment-service provider to match the refund to the particular order and properly document the financial transaction.
The business may not unilaterally replace a monetary refund due with a discount voucher, store credit or another future commercial benefit where this is not permitted by applicable law.
If the consumer expressly agrees to a different lawful means of reimbursement, the agreement must reflect a genuine and clear choice and must not be used to circumvent mandatory rights.
Where the original payment service can no longer be used for technical or other genuine reasons, the Seller examines an appropriate lawful alternative refund procedure.
Legal basis: Article 13(1) of Directive 2011/83/EU.
142. Diminution in value of returned goods and permissible limits of consumer liability
Where the consumer exercises the lawful right of withdrawal from a distance contract for the sale of goods, any liability for diminution in the value of the returned product is determined in accordance with the specific provisions governing that right.
The consumer is liable only for a reduction in value resulting from handling of the goods beyond what is necessary to establish their nature, characteristics and functioning, provided that the prescribed legal conditions are met.
The Seller may examine the actual condition of the returned product and retain appropriate evidence concerning the condition in which it was received.
The existence of wear, alteration or another difference does not automatically give the Seller the right to retain the entire price paid. Any financial claim must be linked to the actual diminution in value and the specific circumstances.
The business may not impose a general, predetermined percentage deduction on every returned product without an individual assessment of its actual condition.
If the Seller has failed to provide the consumer with the required information concerning the right of withdrawal, the specific statutory consequences concerning liability for diminution in value apply.
Legal basis: Article 14(2) of Directive 2011/83/EU.
143. Informing the Customer of a material delay or inability to deliver
Where the Seller becomes aware that a particular order may not be delivered within the agreed period, it ensures that the Customer is appropriately informed of the actual status of the shipment and the available information concerning its progress.
Information may be provided by email, through the order account, via a shipment-tracking service or by another appropriate means of communication.
Where the actual cause of the delay is known, the Seller may communicate the relevant details to the Customer without presenting unverified information as the definitive explanation of the incident.
Where the delay is connected with an actual availability problem, loss of the shipment or another inability to perform, the business must assess its contractual obligations and avoid maintaining inaccurate information about the status of the order.
Informing the Customer of the delay does not automatically mean that the Customer agrees to a new delivery date or waives rights granted by law.
If a new date or a different method of performing the transaction is proposed, the proposal is dealt with in accordance with the rules applicable to the particular contract.
Legal basis: Article 6(1)(g) and Article 18 of Directive 2011/83/EU, together with the general requirements for correct and non-misleading commercial information under Directive 2005/29/EC.
144. Buyer details and collection of information necessary for performance of the transaction
During checkout, the Customer provides the information necessary to carry out the particular transaction, perform the contractual obligations and enable the Seller to comply with applicable legal requirements.
Such information may include the buyer's full name or legal company name, necessary contact details, delivery address, required invoicing information and other data genuinely necessary for the particular purpose.
The business must avoid collecting information that is not necessary for performance of the order or another specific and lawful function.
Where the transaction concerns a natural person, processing of personal data must be based on an appropriate lawful basis and comply with the principles of purpose limitation, data minimisation, accuracy and security.
The existence of a contractual relationship does not automatically justify every form of personal-data processing. Separate functions, such as sending advertising messages, creating an individualised commercial profile or transmitting data for independent purposes of third parties, are assessed separately under the applicable provisions.
Where specific legislation requires the business to collect additional information for a particular category of products or transactions, collection must be limited to the prescribed purpose and corresponding legal requirements.
The Customer is informed about processing of personal data in accordance with the Privacy Policy and the specific information required to be provided during the particular process.
Legal basis: Articles 5, 6 and 13 of Regulation (EU) 2016/679 concerning processing principles, lawful bases and information to data subjects.
145. Product photographs and accurate visual presentation
Photographs displayed in the online catalogue are intended to present products and assist the Customer in identifying and selecting the goods the Customer wishes to purchase.
The Seller may use original photographs created by the Seller, photographs lawfully supplied by manufacturers or suppliers and other photographic material for which the necessary rights of use are held.
The visual presentation must correspond to the material characteristics of the product and must not create a misleading impression concerning the brand, type, dimensions, quantity, packaging or actual subject matter of the sale.
If a photograph depicts more products than are included in the unit of sale offered, the business takes steps to clarify the actual quantity appropriately. Likewise, if a photograph of a different version or package is used, the difference must be disclosed where it is capable of affecting the purchasing decision.
Use of photographic material for commercial presentation does not exempt the Seller from the obligation to deliver goods corresponding to the agreed characteristics. Where a photograph formed a material part of the commercial presentation and created a specific expectation regarding product characteristics, its significance is assessed under the rules governing conformity of goods.
The Customer is not required to accept a product materially different from that agreed merely because the business uses a general notice stating that photographic material is indicative.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning misleading actions and omissions; Articles 6 and 7 of Directive (EU) 2019/771 concerning agreed characteristics, description and conformity with a sample or model.
146. Distinction between the legal guarantee and an additional commercial guarantee
The Seller's statutory liability for lack of conformity of goods applies in accordance with the mandatory provisions governing the particular contract.
A commercial guarantee is an additional commitment that may be provided by the Seller, manufacturer or another guarantor in accordance with the terms and conditions of the relevant guarantee statement.
The existence or absence of a commercial guarantee does not extinguish the consumer's statutory rights against the Seller.
Where a commercial guarantee is offered, the information provided to the Customer must appropriately identify the guarantor, duration, content and procedure for exercising the corresponding rights.
The Seller may not present mandatory statutory rights as a special commercial benefit for which the consumer must pay an additional price.
Where the manufacturer provides an additional commercial guarantee, the Seller is not automatically released from the statutory liability borne in relation to the particular sales contract.
Legal basis: Article 17 of Directive (EU) 2019/771 concerning commercial guarantees and Article 21 of the same Directive concerning the mandatory nature of consumer protection.
147. Selection of shipping method and agreement on the transport service
During the checkout process, the Customer may choose from the available shipping services offered by the Seller for the particular order and selected delivery destination.
The available options may differ in cost, estimated delivery time, service area, collection method and other services included.
The Seller ensures that material information concerning the selected shipping service and the corresponding charges is disclosed to the Customer before final submission of the order.
The Customer's selection of a particular carrier from among the services offered by the Seller does not automatically mean that the Customer assumes the risk of loss of or damage to the goods from the moment they are handed to the carrier.
Transfer of risk takes place in accordance with the applicable provisions and the actual circumstances of the transaction, including the distinction between a carrier offered by the Seller and a carrier independently commissioned by the Customer without being an option offered by the business.
If, after submission of the order, it becomes necessary to use a different transport service, the Seller assesses the consequences for the agreed delivery time, cost and other material characteristics of the transaction.
Use of an independent transport company does not automatically release the Seller from its contractual and legal obligations towards the consumer.
Legal basis: Article 6(1)(g), Article 18 and Article 20 of Directive 2011/83/EU concerning delivery terms, performance of the contract and transfer of risk.
148. Separation of intellectual-property rights by photograph and file
The Seller may organise a central documentation archive of the rights associated with photographic and other creative material used in the online stores.
For each file, its actual origin, creator, right holder, licence, any restrictions and available information concerning permitted forms of publication may be recorded.
Files originally created by the business must be distinguished from those supplied by suppliers, acquired under licence or resulting from the processing of pre-existing material.
Technical processing, resizing, background removal or another alteration of a photograph does not automatically mean that third-party rights in the original work cease to exist.
The business must examine the lawful basis for the use of each file and avoid attributing exclusive rights to itself where the relevant rights belong to a third party.
Legal basis: Articles 2 and 3 of Directive 2001/29/EC and the applicable provisions of Greek Law 2121/1993 on copyright.
149. Product selection and creation of the electronic order
The Customer may select the products they wish to purchase through the online catalogue, according to the options actually available and the characteristics presented on the relevant page for each item.
The selection process may include specifying the desired quantity, the particular version or variant, the packaging and other characteristics that are material to the purchase.
The Seller ensures that the ordering process enables the Customer to identify the products selected and to distinguish between different versions or commercial units where these have material differences.
Where the same product is offered in more than one package or quantity, the relevant choice must be clearly linked to the actual price and the quantity to be delivered.
Selection of a particular product does not give the Seller a general right to replace the item with a different product without the corresponding lawful agreement.
Before finally submitting the order, the Customer must have the opportunity to review the basic details of the purchase and correct any input errors using appropriate technical means.
The information presented during product selection forms part of the pre-contractual information process and is assessed in accordance with the applicable provisions governing the conclusion and performance of the particular transaction.
Legal basis: Article 6(1)(a) of Directive 2011/83/EU concerning information on the main characteristics of the goods; Articles 10 and 11 of Directive 2000/31/EC concerning the technical steps for concluding an electronic contract and the possibility of correcting input errors.
150. Identification, matching and confirmation of payment for a particular order
The Seller organises an appropriate process for identifying and matching payments made through the available financial services so that each payment is linked to the corresponding order and the actual details of the particular transaction.
The process may include use of a unique order number, transaction identifier, information from the payment-service provider or other lawful data enabling verification of the actual payment.
The business may use automated mechanisms to update payment status provided that the relevant information corresponds to the actual data of the competent provider and does not create a misleading impression concerning completion of the financial transaction.
Where a payment cannot be matched automatically to a particular order, the Seller examines the available information and may contact the Customer in order to carry out the necessary identification.
A technical error in the order-status update system does not automatically mean that payment was not made. Likewise, an indication of successful payment is not, by itself, irrebuttable proof of final collection where the provider's information shows a different actual status.
The Seller must examine any dispute concerning payment status and deal with the consequences in accordance with the actual transaction data, agreed terms and applicable law.
Payment data collected for identification and documentation of transactions are retained only to the extent necessary for specific lawful purposes and are protected by appropriate technical and organisational measures.
Legal basis: Article 5(1)(b), (c), (d) and (e), Articles 6 and 32 of the GDPR concerning purpose limitation, data minimisation, accuracy and security of personal data. Articles 64 and 72 of Directive (EU) 2015/2366 concerning authorisation and proof of execution of payment transactions to the extent applicable to the competent providers.
151. Retention of original photographic files and documentation of their creation
The Seller may retain original photographic files lawfully created for the needs of the online store, together with the information necessary to document their creation and processing.
The documentation may include the original photograph, intermediate processing versions, date of creation, creator details and relevant agreements transferring or licensing rights.
The existence of high-resolution files or technical metadata may be used as evidence in the event of a dispute concerning the actual rights in a particular photograph.
Such information does not automatically create an exclusive right in a third party's work where the business does not hold the corresponding lawful rights.
The Seller may use the lawful means available to protect against unauthorised reproduction of photographic material in which it actually holds rights.
Legal basis: Articles 2 and 3 of Directive 2001/29/EC and the applicable provisions of Greek Law 2121/1993 concerning protection of works and photographs.
152. Correction of input errors and possibility of modifying the order before submission
The Seller ensures that the Customer has appropriate, effective and accessible technical means for identifying and correcting input errors before final submission of the electronic order.
This possibility may include changing the quantity of selected products, removing goods from the cart, choosing a different variant and correcting information necessary for invoicing or delivery.
The business must organise the checkout process so that the Customer can review the material information relating to the order before the final stage at which the payment obligation is assumed.
Where correction of a particular item affects the price, shipping costs, availability or another material parameter of the transaction, the relevant changes must be displayed appropriately before final submission.
The mere existence of a facility enabling the Customer to correct errors does not exempt the Seller from responsibility for inaccurate information originating from the Seller's own information system or from the commercial presentation of the products.
If an input error is identified after submission of the order, the possibility of modifying the transaction is assessed according to the stage of conclusion and performance of the contract, the applicable terms and the statutory rights of the contracting parties.
Legal basis: Article 10(1)(c) and Article 11(2) of Directive 2000/31/EC concerning the provision of appropriate technical means for identifying and correcting input errors before an electronic order is placed.
153. Withdrawal statement and lawful methods for communicating the consumer's decision
The consumer exercises the right of withdrawal by informing the Seller of the decision to withdraw from the particular contract in accordance with the procedures laid down by the applicable legislation.
Notification may be made by using the prescribed model withdrawal form or by any other unequivocal statement setting out the consumer's decision to withdraw.
The Seller may not require use of one exclusive form as a general condition for validity of withdrawal where the law permits another unequivocal statement.
The statement must enable identification of the particular contract from which the consumer wishes to withdraw.
The business may request information necessary to identify the order without imposing disproportionate or unlawful procedural conditions.
Withdrawal is regarded as having been exercised within the period where the consumer sent the corresponding statement before expiry of the statutory deadline.
The business may not require that the statement must have been reviewed or approved by its staff before expiry of that period.
Where the consumer uses a lawfully available electronic withdrawal process, the Seller fulfils the corresponding obligations to acknowledge receipt of the statement.
Legal basis: Articles 11 and 12 of Directive 2011/83/EU.
154. Misuse of services and protection of commercial operations
The Seller reserves the right to take lawful and proportionate measures to protect the online store against actions that compromise the security of its services, cause technical damage, alter data or materially obstruct the lawful use of the systems by other visitors.
Where specific and documented indications of unauthorised activity arise, the business may investigate the incident and apply appropriate protective measures according to its nature and seriousness.
Temporary suspension of access to a particular function or account must not be used abusively to prevent the lawful submission of complaints, hinder exercise of the right of withdrawal or avoid fulfilment of contractual obligations.
The Customer retains their legal rights concerning previous transactions even where, for genuine and lawful reasons, the ability to place new orders through a particular online account is restricted.
The business must assess each incident on the basis of the actual facts and avoid general or unjustified sanctions that are unrelated to the specific conduct concerned.
Legal basis: Articles 3, 5 and 6 of Directive 93/13/EEC concerning transparency and unfair contractual terms; Articles 5, 6 and 32 of the GDPR to the extent that security measures involve the processing of personal data.
155. Estimated transit time and actual delivery duration
The Seller may provide information on the estimated transit time of the goods, taking into account the destination, selected shipping service, ordinary transport conditions and actual information supplied by the cooperating carrier.
Where transit time is presented as an estimate, the relevant information must reflect the actual data available and must not create the misleading impression that the Seller unconditionally guarantees a particular delivery date.
The existence of an estimated transit time does not extinguish the agreed delivery deadline or the obligations laid down by applicable law.
Actual transport conditions may be affected by increased shipment volumes, adverse weather conditions, temporary transport disruptions, customs checks or other events objectively affecting the particular route.
The existence of such events does not automatically mean that the Seller is released from all liability or that the Customer must wait indefinitely for performance of the transaction.
If delivery does not take place within the agreed or statutory period, the corresponding Customer rights and prescribed procedures for dealing with the delay apply.
Legal basis: Article 6(1)(g) and Article 18 of Directive 2011/83/EU concerning information on time limits and performance of the delivery obligation.
156. Dimensions, technical characteristics and different product types
Products offered through the online store are presented with the information necessary to identify the particular goods and distinguish them from other products in the same or a similar commercial category.
Where dimensions, weight, material, form, size, quantity or other technical characteristics are material to the Customer's choice, the Seller takes steps to ensure that the relevant information is presented with sufficient clarity and corresponds to the actual characteristics of the product offered.
In particular, for products such as rolling papers, filters, paper tips, tubes and related accessories, the description may include dimensions, type, thickness, quantity per pack and other characteristics material to identification of the particular version.
Information provided by the manufacturer or supplier may be used as the basis for the commercial description. If, however, a particular characteristic is found to have been presented inaccurately, the Seller must examine the discrepancy and deal with its consequences in accordance with contractual obligations and applicable law.
The existence of minor manufacturing tolerances or variations does not confer a general right to deliver a product with materially different characteristics from those agreed. Each deviation is assessed according to the nature of the product, the information provided before purchase and its significance for the particular transaction.
The Customer retains statutory rights where the delivered goods do not correspond to the description, type, quantity or other agreed characteristics.
Legal basis: Article 6(1)(a) of Directive 2011/83/EU concerning information on the main characteristics of goods; Articles 5, 6 and 7 of Directive (EU) 2019/771 concerning subjective and objective conformity requirements for goods.
157. Instructions for use, safety warnings and appropriate information for the Customer
Products made available through the online store must be accompanied by the instructions for use, safety warnings and other information required by the applicable regulatory framework for the particular category of goods.
The Seller must take into account the nature of the product, its ordinary or reasonably foreseeable use, risks that may be associated with it and the relevant information provided by the manufacturer or another competent economic operator.
Where a particular product is subject to specific rules on safety, labelling, use, transport or storage, the business must examine the corresponding requirements before making it available on the market.
Instructions and warnings that must be communicated during a distance offer are presented clearly and in a manner appropriate to the product category and the country in which it is made available.
Provision of instructions for use or warnings does not exempt the Seller from statutory obligations concerning the safety and conformity of the goods.
The Customer is expected to use the product according to its intended purpose and the relevant safety instructions. However, product use is assessed on the basis of the actual circumstances and every instance of damage or problem may not automatically be attributed to misuse without appropriate evidence.
Legal basis: Article 19(d) of Regulation (EU) 2023/988 concerning safety information required in distance offers; Articles 6 and 7 of Directive (EU) 2019/771 concerning delivery of the agreed and reasonably expected instructions and accessories.
158. Environmental claims, recyclability and sustainable production
Environmental claims used in presenting products must be specific, accurate and appropriately substantiated so as not to create a misleading impression concerning the actual environmental footprint or properties of the particular goods.
Where a product is described as recyclable, biodegradable, made from recycled materials or manufactured using a particular environmentally oriented method, the commercial presentation must correspond to the actual substance of the claim and the evidence supporting it.
The business must avoid presenting a single environmental characteristic as general proof that the product as a whole or the commercial activity has no environmental impact where such a conclusion is not justified by the available data.
Environmental-certification indications, quality marks or other distinctive signs suggesting independent assessment are used only where the corresponding lawful basis exists and the conditions for their use are satisfied.
The Seller may retain documentation supporting the environmental claims it uses, including relevant manufacturer information and certifications that genuinely concern the particular product.
If the actual characteristics of the goods, the regulatory framework or the evidence on which an environmental claim is based change, the business examines the need to revise the commercial presentation and to avoid continuing to use inaccurate or insufficiently substantiated statements.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning unfair commercial practices. In addition, Directive (EU) 2024/825 strengthens requirements relating to environmental claims and provides for application of the relevant national measures from 27 September 2026, which must be taken into account before publication and future use of the corresponding commercial descriptions.
159. Discounts, previous price and transparency of commercial presentation
Where the Seller announces a reduction in the price of a particular product, the commercial presentation must comply with the applicable requirements concerning indication of the previous price and calculation of the actual discount.
In cases falling within Article 6a of Directive 98/6/EC, the previous price is, as a rule, determined by reference to the lowest price applied by the trader during the required period before the announcement of the reduction.
For application of this requirement, the corresponding national rules are taken into account, including specific cases in which a different calculation of the previous price is permitted.
The business may not present an artificially inflated reference price for the purpose of creating a misleading impression of a greater financial benefit to the Customer.
Where successive price reductions are made or the same product participates in several promotional activities, the Seller must examine the correct application of the rules for calculating the previous price.
Use of a discount percentage, crossed-out price, commercial label or other visual element must not create an inaccurate impression concerning the actual financial benefit of the purchase.
The Seller may maintain an appropriate price history so that it can document the accuracy of the relevant commercial claims and address any disputes.
Legal basis: Article 6a of Directive 98/6/EC. The general European basis for the previous price is the lowest price during at least the preceding 30 days, subject to the specific exceptions and national rules provided for.
160. Relationship between the General Terms and the store's specific policies
These General Terms and Conditions constitute the basic contractual framework governing the online purchase of products from the store and apply together with the more specific information provided to the Customer during the transaction process.
Specific policies concerning shipping, payments, returns, the right of withdrawal, personal-data protection and the use of cookie technologies further specify the corresponding matters to the extent relevant to the particular transaction or use of the website.
The existence of a specific policy does not release the Seller from the obligation to provide the pre-contractual information required by applicable law and does not permit material restrictions to be hidden in parts of the website that are not appropriately accessible to the Customer.
Where a particular transaction is subject to special terms, such as a specific wholesale agreement, a customised order or a particular transport service, the corresponding information must be communicated to or agreed with the buyer before the relevant contractual obligations are undertaken.
In the event of inconsistency between a general and a specific contractual provision, interpretation is carried out in accordance with applicable law, the actual content of the agreement and mandatory consumer-protection rules.
Legal basis: Article 6(1) and (5) of Directive 2011/83/EU concerning pre-contractual information and incorporation of the relevant information into the distance contract; Articles 3–6 of Directive 93/13/EEC.
161. Duplicate charge, repeated payment and investigation of erroneous collection
Where the Customer finds that they may have been charged more than once for the same order, they may contact the Seller through the available means of communication and provide the information necessary to investigate the incident.
The Seller examines the available order data, information supplied by the competent payment-service provider and other information enabling verification of the actual number and status of the relevant transactions.
The investigation must distinguish an actual duplicate collection from a temporary authorisation hold that has not become a final charge or another intermediate payment process.
Where it is established that the Seller collected amounts exceeding those lawfully due under the particular transaction, the business must address reimbursement of the amounts unduly paid in accordance with applicable law.
Reimbursement of an amount collected without lawful or contractual basis may not be made arbitrarily conditional on acceptance of additional commercial terms, completion of a new purchase or receipt of store credit instead of a monetary refund where such a condition is not permitted by law.
Where the second apparent charge relates to an error or intermediate process of an independent payment provider, the Seller cooperates with the competent provider to the extent required to investigate and remedy the incident, without automatically assuming liability for every independent act of a third party.
The business may retain the necessary documentation of the investigation and refund made, in accordance with applicable accounting and tax obligations and personal-data-protection requirements.
Legal basis: Articles 64, 71 and 89 of Directive (EU) 2015/2366 concerning authorisation, identification and correction of unauthorised or incorrectly executed payment transactions. Articles 904 et seq. of the Greek Civil Code on unjust enrichment where Greek law applies and the relevant conditions are met.
162. Cross-border distance sales and specific restrictions
Online sale of products to buyers located in a different country constitutes a cross-border transaction whose lawfulness must be assessed on the basis of the actual product, the Seller's place of establishment, the place of delivery and the applicable legislative framework.
The business must take into account that particular categories of goods may be lawfully sold in physical stores but be subject to additional restrictions or prohibitions on cross-border distance supply.
The existence of the European single market does not exclude the application of specific restrictions lawfully laid down for particular product categories.
The Seller may not assume that use of a different domain, a different language version, a foreign payment provider or another technical route automatically changes the law applicable to the actual transaction.
Where sale of a particular product is subject to specific conditions, the business organises the commercial presentation and checkout process in accordance with the actual lawful possibilities for making that product available.
A general statement of compliance with the law is not, by itself, sufficient to make lawful a transaction prohibited by a specific provision.
Legal basis: Article 18 of Directive 2014/40/EU and the corresponding national provisions applicable by product and country of destination.
163. Minor lack of conformity and specific limitations on the right to terminate the contract
Where the lack of conformity of a particular product is only minor, the possibility of terminating the contract is assessed in accordance with the specific restrictions laid down by applicable law.
The assessment is carried out by reference to the nature of the goods, the significance of the particular deviation and the actual circumstances of the transaction.
The Seller may not arbitrarily characterise a lack of conformity as minor solely in order to avoid refunding the price or another legal obligation.
The existence of a small external difference does not automatically mean that the lack of conformity is minor if the difference materially affects the agreed product or the purpose of the purchase.
Likewise, the existence of any insignificant variation does not automatically establish a right to terminate the entire contract.
The burden of proving that the lack of conformity is only minor rests with the Seller, in accordance with Article 13(5) of Directive (EU) 2019/771.
The other lawful remedies available are assessed according to the particular circumstances and applicable provisions.
Legal basis: Article 13(2)–(5) of Directive (EU) 2019/771.
164. Limited promotional stock and avoidance of misleading commercial practices
Where a particular commercial offer is linked to limited product stock, the presentation must correspond to the actual quantities available and must not create a false impression of artificial scarcity.
The Seller may set a maximum number of products available, a duration for the offer or other objective limitations provided that they correspond to the actual circumstances and are appropriately disclosed to the Customer.
Commercial statements suggesting an exceptionally limited time or stock must not be used in a manner that creates a misleading impression concerning availability or an actual need to purchase immediately.
Where the ability to fulfil the offer depends on a third-party supplier, the Seller must take actual availability information into account before accepting orders.
If the quantity offered is exhausted, the business may discontinue the ability to submit new orders on those commercial terms without this automatically altering obligations already undertaken.
The business may not use inaccurate stock information as a general justification for arbitrarily cancelling binding contracts or replacing agreed products with different goods.
Legal basis: Articles 6 and 7 and Annex I to Directive 2005/29/EC concerning misleading commercial practices, presentation of limited availability and creation of an inaccurate impression regarding the need for an immediate purchase.
165. Proven use of a product and consequences of handling beyond necessary examination
Where the consumer returns a product after exercising the right of withdrawal, the Seller may examine whether handling has taken place beyond what is necessary to establish the nature, characteristics and functioning of the goods.
The assessment is carried out by reference to the particular product, the ordinary way in which it may be examined and the actual actions taken after delivery.
A mere suspicion that a product was used is not, by itself, sufficient to establish a particular financial claim. The Seller must rely on factual evidence and distinguish permissible examination from use exceeding what is necessary.
If an actual diminution in value resulting from such handling is proven, the consumer's corresponding liability is determined in accordance with the legal conditions.
The business may not assume that the existence of any trace of handling automatically entails complete loss of the right of withdrawal.
Actual consumption of goods, diminution in their value and application of a specific statutory exception to withdrawal are separate issues that must be assessed according to the nature of the product and applicable law.
Legal basis: Article 14(2) and Article 16 of Directive 2011/83/EU.
166. Refund of amounts paid without lawful or contractual basis
The Seller has no right permanently to retain a sum of money where, according to the actual circumstances and applicable law, there is no lawful or contractual basis justifying the particular payment or its retention.
An obligation to refund may arise, as applicable, from duplicate payment, an erroneous charge, failure to complete a transaction, lawful termination of the contract or another factual and legal basis.
The business assesses each request on the basis of the details of the particular transaction and distinguishes cases in which a specific time limit or refund procedure applies from those governed by the general rules of contract law.
Where the consumer lawfully exercises the right of withdrawal, the refund is made in accordance with the specific requirements of distance-contract legislation, including the prescribed time limits, the appropriate means of reimbursement and the possibility of lawfully awaiting receipt of the returned goods where applicable.
In the event of lawful termination of a contract due to non-delivery or lack of conformity, the specific consequences provided for in the corresponding case apply.
The Seller may not assume that the existence of a general commercial no-refund policy excludes cases in which the law requires a mandatory refund.
Payment of an amount without lawful or contractual basis does not automatically give the Seller the right to impose an additional financial charge on the Customer in order to correct the corresponding erroneous collection.
Legal basis: Article 13 of Directive 2011/83/EU concerning refund obligations in the event of withdrawal and Article 18(3) concerning reimbursement of amounts paid following termination for non-delivery. Articles 904 et seq. of the Greek Civil Code on unjust enrichment, where applicable.
167. Online withdrawal function through the website
Where the contract falls within the scope of the provisions on distance contracts and has been concluded through an online interface, the Seller must provide the electronic withdrawal function required by the applicable legislation.
The function must allow the consumer to communicate electronically the decision to withdraw from the particular contract without requiring disproportionate technical or procedural means.
The withdrawal facility must be easily accessible and prominently displayed on the online interface throughout the corresponding period for exercising the right.
The electronic process must allow the consumer to provide or confirm the information necessary to identify the particular contract and to send the corresponding confirmation.
The Seller must provide a clear function for final confirmation of submission of the withdrawal statement in accordance with the specific requirements of the applicable regulatory framework.
Completion of the electronic procedure may not depend on mandatory telephone contact not provided for by law, personal attendance or another process that makes exercise of the right disproportionately difficult.
The existence of an electronic withdrawal function does not exclude the other lawful means of communicating the consumer's decision.
Legal basis: Article 11a of Directive 2011/83/EU, as inserted by Article 1 of Directive (EU) 2023/2673. The corresponding national implementing provisions are expected to apply from 19 June 2026.
168. Partial invalidity and preservation of the remaining contractual provisions
Where a particular provision of these General Terms and Conditions is found to be invalid, unfair or unenforceable, the consequences of that finding for the remainder of the contract are determined in accordance with applicable law.
Invalidity of a particular provision does not automatically result in invalidity of the entire contract where the contract can continue to exist under the applicable rules.
The Seller may not rely on a general severability clause in order to preserve effects arising from an unfair term or unilaterally replace an invalid provision with another provision imposing a corresponding unlawful restriction on the Customer.
Contractual obligations that remain valid after a particular invalid provision has been dealt with are performed in accordance with the remainder of the lawful agreement and the applicable mandatory provisions.
This provision does not restrict the Customer's ability to challenge the lawfulness of other contractual terms and does not predetermine the consequences that invalidity of a particular provision may have for the validity of the entire contract.
Legal basis: Article 6(1) of Directive 93/13/EEC, under which unfair terms are not binding on the consumer while the contract may continue to exist if it is capable of doing so without those terms.
169. Product identification and use of commercial codes
Every product presented in the online catalogue must be capable of being identified with sufficient clarity so that the Customer knows which specific item is being purchased and can distinguish its different versions or variants.
For this purpose, the business may use trade names, manufacturer codes, internal stock codes, product-identification numbers and other elements that support the correct presentation and management of the goods.
Internal codes used by the business's information system are intended to organise the catalogue, monitor stock and match products to particular orders.
Use of a different internal code for the same product across more than one online store does not automatically mean that the actual characteristics of the goods differ, nor does it create a right to replace them with a different product.
Where required by applicable law, the presentation and accompanying documentation of the product include the necessary identification and traceability information.
Legal basis: Article 19(c) of Regulation (EU) 2023/988 concerning identification of products in distance offers falling within its scope; Article 6 of Directive (EU) 2019/771 concerning the description, type and quantity of the agreed goods.
170. Amendment, revision and temporal effect of the General Terms
The Seller retains the ability to revise and amend these General Terms and Conditions where necessary in order to adapt the operation of the online store to changes in legislation, available services, commercial processes or other actual circumstances.
Each new version of the terms is published in a manner that allows visitors and Customers to become informed of its content before entering into a new transaction.
Amendments apply to contracts concluded after they enter into force, unless otherwise lawfully agreed or a different consequence arises from a mandatory legislative provision.
A subsequent amendment to the terms does not give the Seller the right unilaterally to change the agreed price, material characteristics of the products, delivery time or other fundamental elements of a contract already concluded, except where such a change is lawfully permitted.
The Seller organises an appropriate process for retaining previous versions so that the contractual terms applicable to a particular order can be determined.
Mere continued browsing of the website after publication of a new version is not automatically regarded as acceptance of a material amendment to an existing contract where a specific lawful agreement of the parties is required.
Legal basis: Articles 3 and 6 and the Annex to Directive 93/13/EEC concerning unfair contractual terms and terms allowing unilateral amendment of contracts.
171. Commencement and calculation of the statutory withdrawal period
For ordinary distance contracts for the sale of goods, the withdrawal period is, as a rule, fourteen days and is calculated in accordance with the specific rules applicable to the particular type of transaction.
In the case of a sale of goods, the period generally begins on the day on which the consumer or a third person designated by the consumer, other than the carrier, acquires physical possession of the goods.
The date on which the order was submitted, payment was made or the parcel was handed to the carrier does not automatically constitute the starting date of the withdrawal period for an ordinary contract for the sale of goods.
Where special provisions apply to multiple goods, separate deliveries or split shipments, the period is calculated in accordance with the corresponding specific rules.
The Seller must provide the required information concerning the right of withdrawal before conclusion of the contract.
If the Seller fails to provide the mandatory information concerning the right of withdrawal, the specific statutory consequences extending the period apply.
The business may not arbitrarily shorten the withdrawal period by calculating it from an earlier event where the law provides for a different starting point.
Legal basis: Article 6(1)(h), Articles 9 and 10 of Directive 2011/83/EU.
172. Tax treatment of cross-border sales, intra-EU distance transactions and retention of financial records
The tax treatment of products sold through the online store is determined by reference to the actual Seller, the status of the buyer, the nature of the goods, the place from which dispatch takes place and the final destination of the particular transaction.
Where the business carries out intra-EU distance sales of goods to consumers in other Member States of the European Union, it considers the rules determining the place of taxation of the transaction and the applicable obligation to account for VAT.
The possibility of using the One Stop Shop (OSS) special scheme is assessed in accordance with the actual conditions governing the business's eligibility and the transactions covered by that scheme.
The existence of an online store in a particular language or the use of a web address with the country-code domain of another country does not, by itself, determine the tax treatment of the particular sale.
The business must monitor its actual cross-border transactions and assess the application of the relevant thresholds, exemptions and special tax procedures on the basis of the conditions applicable to the particular taxable person.
Where goods are dispatched from a third country to a consumer established in the European Union, the business separately considers the customs and tax obligations associated with importation and the corresponding commercial transaction.
The Seller may use a central information system for recording orders, payments, tax information, actual countries of delivery and other information necessary for fulfilment of its tax obligations.
The business must retain the required financial and tax records for the periods prescribed by applicable provisions, while ensuring appropriate protection of the personal data contained in those records.
Use of a central management system for several online stores does not release each actual taxable entity from the obligations associated with its own transactions.
Legal basis: Articles 33 and 59c of Directive 2006/112/EC concerning the place of taxation and the specific conditions relating to the EU-wide threshold of EUR 10,000, as well as Articles 369a–369k of the same Directive concerning the Union OSS special scheme. Articles 242–244 concerning the keeping of financial and tax records.
173. Return, export and deletion of data after termination of cooperation with a technical provider
Where the business entrusts a third-party provider with hosting, management or processing of data connected with operation of the online store, it must define the corresponding contractual obligations according to the actual roles of the parties involved.
Where the provider acts as a processor of personal data on behalf of the business, the requirements of Article 28 of the GDPR apply.
The relevant agreement must specify, among other matters, the provider's obligations upon termination of the cooperation, including return or deletion of personal data in accordance with the legal conditions and the controller's instructions.
The business may additionally provide for contractual procedures for exporting commercial data, the product catalogue, content files and other information lawfully forming part of its operational infrastructure.
Data must not be deleted in breach of a mandatory legal retention obligation.
Legal basis: Article 28(3)(g) of the GDPR concerning return or deletion of personal data after the end of the provision of processing services.
174. Restrictions on advertising, commercial promotion and product presentation
The lawfulness of selling a particular item does not automatically mean that every form of advertising, commercial promotion or presentation of it through the website, search engines, social networks or third-party electronic platforms is permitted.
The Seller must distinguish ordinary commercial presentation necessary to identify a product from specific advertising practices that may be subject to additional lawful restrictions.
Where a particular product category is subject to special advertising rules, the business examines the permitted forms of presentation, relevant warnings and restrictions applicable in the corresponding market.
Use of translated content, a different domain or advertising services supplied from a third country does not release the Seller from obligations connected with the actual commercial activity and the audience to which it is directed.
Commercial communication must also avoid inaccurate claims concerning the nature, composition, safety or properties of products and avoid creating a misleading impression concerning official approvals or commercial relationships.
The business retains the ability lawfully to inform its customers about products it makes available to the extent that the particular presentation is permitted by the provisions applicable to the product, form of communication and destination market.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning misleading commercial practices and the specific advertising provisions applicable to product categories falling within the corresponding regulatory framework.
175. Retention of compliance evidence, protection of lawful business activity and response to unjustified restrictions
The Seller retains the ability to protect its lawful business activity and use the prescribed means of challenging decisions or actions that may unjustifiably restrict access to services or the making available of its products.
The business may organise a documentation file of the actual compliance measures it applies, including product-origin records, relevant documents, safety information, lawful licences to use commercial content and documents evidencing the particular commercial activity.
Where a notice is received from an online platform, hosting-service provider or another competent entity concerning a possible breach of a legal or contractual obligation, the Seller may examine the actual content of the notice and provide appropriate information through the available procedures.
The business may seek lawful review of a particular restriction where it possesses factual evidence supporting that the relevant decision was based on inaccurate information, erroneous product classification or another defective assessment.
The existence of a right to challenge does not create general immunity from lawful restrictions and does not permit circumvention of binding decisions of competent authorities.
The Seller must cooperate with competent authorities and relevant service providers where legally required while retaining the ability to exercise rights of administrative or judicial protection available to it.
Compliance documentation must reflect measures actually implemented and must not be limited to general website statements that do not correspond to the real operation of the business.
Protection of lawful business activity is pursued through accurate documentation, actual compliance, lawful challenge of specific restrictions and exercise of available rights, without limiting obligations towards consumers, third-party right holders or competent authorities.
Legal basis: Articles 16, 17, 20 and 21 of Regulation (EU) 2022/2065 to the extent applicable to the relevant provider and particular decision, and Articles 4 and 11 of Regulation (EU) 2019/1150 for covered online intermediation services.
176. Payments by debit or credit card and security of the electronic transaction
Where the Customer chooses to pay by debit card, credit card or another accepted payment card, the financial transaction is carried out through the corresponding payment service supported by the online store.
The Seller may cooperate with licensed payment-service providers and financial institutions for accepting and processing electronic payments. The involvement of those providers does not automatically alter the identity of the actual Seller or extinguish the obligations arising from the contract for the purchase of the goods.
During the transaction, an additional identification or confirmation procedure may be required by the relevant provider in accordance with the applicable security requirements. The process may include use of specific transaction-confirmation mechanisms intended to verify authorisation of the payment.
The Seller must organise the connection between the online store and payment services in a manner that reduces the risk of unauthorised access, alteration of transaction data or exposure of personal data.
Use of an external payment service does not justify the Seller collecting or storing more financial data than are necessary for fulfilling its actual contractual, accounting and legal obligations.
The business must not ask the Customer to disclose, by email, a simple contact form or another unsuitable means, personal online-banking credentials or secret card confirmation codes.
Successful authorisation of a payment does not automatically mean that the corresponding order has been delivered or that all other obligations of the Seller have been fulfilled. The financial transaction and performance of the purchase contract are distinct processes connected with the particular order.
Legal basis: Articles 64 and 97 of Directive (EU) 2015/2366 concerning consent to execute a payment transaction and strong customer authentication. Article 32 of Regulation (EU) 2016/679 concerning the implementation of appropriate technical and organisational security measures when processing personal data.
177. Proportionate price reduction due to lack of conformity
Where the legal conditions are met, the consumer is entitled to a proportionate reduction in price in the event of lack of conformity of the goods.
The reduction must correspond to the decrease in value of the goods received by the consumer compared with the value the goods would have had if they conformed to the contract.
The Seller must examine the actual nature and extent of the lack of conformity without applying an arbitrary reduction percentage unrelated to the particular case.
The possibility of a price reduction is not automatically limited to cases in which the Seller wishes to grant a commercial discount.
It is a statutory remedy applicable subject to the specific conditions of Article 13 of Directive (EU) 2019/771.
Where the price has already been paid in full, the corresponding financial adjustment is made in accordance with the legal consequences of the particular reduction.
Legal basis: Articles 13 and 15 of Directive (EU) 2019/771.
178. Order preparation time, packaging process and commencement of shipment
After conclusion of the contract and fulfilment of the agreed payment conditions, the Seller organises preparation of the ordered products and the procedures necessary to carry out shipment.
Preparation may include checking actual availability, matching products to the particular order, checking quantities, packaging, issuing the required documents and handing the parcel to the selected carrier.
Preparation time must be distinguished from physical transport time where that distinction is necessary to provide the Customer with accurate information concerning the actual delivery time.
Where fulfilment of the order depends on availability from an external supplier, the business must take the actual procurement conditions into account when determining the agreed delivery period.
The existence of an internal preparation process does not confer on the Seller a general right to extend delivery indefinitely. The time required to collect and package the products must be included in performance of the agreed contractual obligation.
If an incident arises that materially affects the ability to perform on time, the Seller examines the need to inform the Customer and the consequences laid down by the contract and applicable legislation.
Legal basis: Article 6(1)(g) and Article 18(1) of Directive 2011/83/EU. The Directive provides for delivery without undue delay and, unless a different time has been agreed, within 30 days from conclusion of the contract.
179. Delivery address details and proper execution of shipment
During the ordering process, the Customer provides the delivery information necessary for carrying out the agreed shipment, in accordance with the transport services actually available and the requirements of the particular transaction.
The delivery address must contain the information required to identify the destination, communicate with the recipient and complete delivery through the selected transport service.
The Seller may use appropriate mechanisms to check the completeness of the delivery information in order to reduce input errors that may cause delay, unsuccessful delivery or return of the parcel.
Where a particular item of information is found to be incomplete or manifestly inaccurate, the business may contact the Customer for the necessary clarification before the shipment is carried out.
If the Customer requests a change to the delivery address after submitting the order, the possibility of making the change is assessed according to the stage of performance of the transaction, the actual capabilities of the carrier and the applicable contractual obligations.
Where delivery is affected by inaccurate information provided by the Customer, the consequences are assessed by reference to the actual cause of the problem, the actions of the contracting parties and the obligations applicable to the particular transaction.
The existence of an incorrect address does not allow the Seller automatically to attribute every loss or delay to the Customer where the problem is due to another cause or to a breach of an obligation resting on the Seller itself.
Legal basis: Article 6(1)(g) and Articles 18 and 20 of Directive 2011/83/EU concerning delivery terms, performance of the delivery obligation and transfer of risk.
180. Review of commercial descriptions generated by artificial intelligence
The Seller may use artificial-intelligence tools to create, translate, process and adapt commercial product descriptions.
Use of such tools does not release the business from its obligation to provide the Customer with accurate, clear and non-misleading information.
Before publication, material information generated or modified automatically must be appropriately checked against the actual characteristics of the particular product.
Particular care is required in relation to information concerning composition, dimensions, quantity, country of origin, safety, certifications and compatibility of the goods.
The Seller may not use claims generated by an automated system as independent proof that a particular product has a certification or characteristic that has not in fact been verified.
If a published description is found to contain a material error, the business considers its correction and the consequences for transactions that have been affected.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC and Articles 6–7 of Directive (EU) 2019/771.
181. Discount coupons, promotional codes and redemption terms
The Seller may provide discount coupons, electronic promotional codes or other means of granting a particular commercial benefit, provided that the related promotion is lawful for the product and transaction to which it applies.
Redemption conditions must be clearly disclosed and enable the Customer to know the actual value of the discount offered, its period of validity and any restrictions associated with its use.
Where a particular code is valid only for certain product categories, a specific order value or a limited number of uses, the corresponding conditions must be appropriately presented before completion of the purchase.
The business may use technical mechanisms to verify coupon validity so as to prevent the use of expired, invalid or already redeemed codes.
In the event of a technical error affecting correct application of an offer, the Seller examines the particular transaction on the basis of the offer terms, actual order status and applicable law.
The ability to cancel or restrict a discount programme for future transactions does not provide a general right unilaterally to alter the agreed price of a contract already concluded.
General coupon terms do not permit imposition of unjustified restrictions or additional charges that were not appropriately disclosed to the Customer.
Legal basis: Articles 6 and 7 of Directive 2005/29/EC concerning accuracy of commercial information, and Article 6(1)(e) of Directive 2011/83/EU concerning information on the total price of the transaction.
182. Termination of the contract due to lack of conformity and reimbursement of the price paid
The consumer is entitled to seek termination of the sales contract where the specific conditions laid down by the applicable legislation are met as a result of lack of conformity of the goods.
Termination may be justified, as applicable, where the Seller has not provided the required remedy, where the lack of conformity persists despite an attempt to remedy it or where the seriousness of the lack of conformity justifies immediate exercise of the corresponding right.
The business examines the actual circumstances and the specific conditions determining whether termination is available.
Where the contract is lawfully terminated, the corresponding obligations concerning return of the goods and reimbursement of the price paid apply in accordance with the provisions governing the particular case.
The Seller may not unilaterally replace a monetary reimbursement due with a discount voucher or credit balance where the consumer is entitled to a different remedy.
The business retains the ability to contest a request for termination where the statutory conditions are not satisfied, on the basis of specific factual and evidential material.
Legal basis: Article 13(4)–(5) and Article 16 of Directive (EU) 2019/771.
183. Return of goods by a customs authority and treatment of an impermissible import
If a particular international shipment is returned, detained or refused entry into the country of destination, the Seller examines the actual cause of the incident and the relevant obligations arising from the particular transaction.
The treatment may differ depending on whether the problem results from an import prohibition, incomplete customs documentation, inaccurate information or failure to fulfil an obligation resting on a particular contracting party.
The business may cooperate with the carrier, customs representative and competent authorities in order to determine the status of the goods and the lawful options available for dealing with the matter.
In B2B transactions, allocation of additional costs is assessed in accordance with the specific commercial agreement and applicable law.
In consumer transactions, every financial consequence may not generally be passed on to the Customer regardless of the Seller's actual obligations.
Legal basis: Regulation (EU) No 952/2013 and Articles 6 and 18 of Directive 2011/83/EU to the extent applicable to the particular transaction.
184. Proof of delivery and assessment of actual receipt
The Seller may retain lawfully available information connected with performance of a shipment so that incidents involving loss, disputed delivery or another irregularity during transport can be investigated.
Such information may include the shipment number, date on which the parcel was handed to the carrier, available tracking information and corresponding proof of receipt.
The existence of an electronic delivery indication, signature or other item provided by the carrier is assessed according to the actual circumstances and is not automatically regarded as irrebuttable proof of performance of the contract.
If the Customer states that the order was not received, the Seller examines the particular report and available evidence without automatically rejecting the claim solely on the basis of the parcel's electronic status.
The business may request from the carrier additional information necessary for the investigation to the extent that its provision and processing are lawful.
Where it is established that delivery did not take place in accordance with the contract, the corresponding rights of the Customer and obligations of the Seller apply.
Legal basis: Articles 18 and 20 of Directive 2011/83/EU and Articles 5 and 6 of the GDPR to the extent that proof of delivery contains personal data.
185. Partial product availability and possibility of partial fulfilment of an order
Where a particular order includes several products and some are found not to be immediately available, the Seller examines the possibility of performing the transaction according to actual availability and the terms agreed with the Customer.
The business may propose split delivery, separate shipment of available products or later delivery of the remaining goods, provided that the relevant procedure is lawfully agreed and does not arbitrarily alter material obligations of the transaction.
Where partial delivery was already provided for when the contract was concluded, it is carried out in accordance with the terms communicated to the Customer and the applicable provisions.
If partial delivery is proposed for the first time after conclusion of the contract, the Seller must assess whether the Customer's specific agreement is required for the relevant modification.
The business may not impose additional transport costs solely because it decided to ship the products in an order separately where those additional costs are not lawfully provided for by the agreement.
Partial performance does not release the Seller from the obligation to deliver the remaining agreed goods within the applicable time limits.
Where the contract is lawfully terminated in relation to particular goods, the consequences for the remaining products are assessed on the basis of the nature of the transaction, whether the remainder of the agreement can continue and the relevant mandatory provisions.
Legal basis: Articles 6 and 18 of Directive 2011/83/EU concerning pre-contractual information and delivery. Article 16(2) of Directive (EU) 2019/771 where termination of the contract is connected with lack of conformity of particular goods.
186. Product availability and accuracy of stock information
Availability information displayed in the online catalogue is intended to inform the Customer about the possibility of ordering and receiving the goods offered. The Seller takes reasonable steps to ensure that the relevant indications correspond, as far as possible, to actual stock data and the available information from its suppliers.
The business may use central product-management information systems, automated stock updates, electronic links with suppliers and other appropriate technical processes to monitor the availability of goods offered for sale.
Where a particular product is not held in the Seller's physical stock and its availability depends on a third-party supplier, the corresponding commercial presentation must be organised so as not to create a misleading impression regarding the possibility of immediate delivery.
Adding a product to the electronic shopping cart does not automatically reserve a particular quantity of stock, unless such reservation is provided for by the actual process of the store or by the agreement concluded with the Customer.
If, after an order has been placed, it is established that a particular product is unavailable, the Seller must inform the Customer without undue delay and examine the possibility of performing the transaction in accordance with the agreed terms and the applicable provisions.
Lack of stock does not confer a general right to replace the product unilaterally, arbitrarily change the agreed price or extend the delivery period indefinitely. The relevant consequences are determined by the stage at which the contract was concluded, the actual cause of the inability to perform and the Customer's statutory rights.
Legal basis: Article 6(1)(b) of Directive 2005/29/EC concerning misleading presentation of product availability, and Article 6(1)(g) and Article 18 of Directive 2011/83/EU concerning pre-contractual information and delivery of goods.
187. Different versions, types and variants of the same product
Where a product is available in more than one version, differences concerning size, quantity, packaging, materials, function or other material characteristics must be presented in a manner that allows the Customer to select the particular version the Customer wishes to purchase.
Use of a common trade name or inclusion of several versions in the same product family does not mean that the different versions are automatically equivalent for the purposes of the particular transaction.
For example, different packs of the same type of paper containing different numbers of sheets or booklets must be appropriately distinguished in the commercial presentation and in the order record.
The Seller is required to deliver the version agreed with the Customer unless the contract is lawfully and appropriately documented as having been amended.
Delivery of another version, even where it belongs to the same brand or commercial family, is assessed on the basis of the agreement and the actual characteristics of the goods.
Legal basis: Articles 5 and 6 of Directive (EU) 2019/771 concerning the obligation to deliver goods corresponding to the description, type, quantity, quality and other agreed characteristics.
188. Dangerous products and temporary suspension of commercial availability
Where credible information arises that a particular product may present a risk to consumer health or safety, the Seller must examine the incident and take the measures required by the nature of the risk and the applicable legal obligations.
Temporary suspension may concern a particular product, batch or range of goods where the available information links the reported risk to those specific products.
The Seller ensures that the assessment is based on the actual identity of the product, available manufacturer or supplier information and relevant information from the competent authorities.
A report concerning a particular batch does not automatically mean that all products of the same commercial brand present the same risk. The scope of the measures required is determined by the actual facts and the applicable guidance or decisions.
Where the Seller has already made affected products available, it examines its obligations to inform buyers, cooperate with the relevant economic operators and notify authorities corresponding to its actual role.
These procedures do not replace or restrict the legal rights of Customers who have purchased dangerous or non-conforming goods.
Legal basis: Articles 5, 9, 11 and 12 of Regulation (EU) 2023/988 concerning the general safety requirement and the corresponding obligations of economic operators.
189. Choice of return carrier and procedure for shipping returned products
The consumer may return goods that are the subject of a lawful withdrawal in accordance with the applicable provisions and the appropriate practical information provided by the Seller.
The business may offer a particular return service, provide a shipping label or organise collection of the goods, provided that the service corresponds to the actual terms of the transaction.
Where the Seller provides an optional return service, the existence of that service must not create the misleading impression that the consumer is deprived of every other lawful method of return.
The business may provide instructions concerning appropriate packaging, order identification and necessary delivery information without imposing disproportionate conditions that are not legally required.
Where the consumer selects a different transport service, the corresponding consequences are assessed on the basis of the actual circumstances and applicable legislation.
The Seller may not arbitrarily refuse application of the statutory right of withdrawal solely because a particular carrier was not used where that requirement is not a lawful condition for exercising the right.
The Seller's ability to wait until the goods have been received or proof of dispatch has been supplied before making reimbursement applies subject to the specific limitations in Article 13(3) of Directive 2011/83/EU.
Legal basis: Article 13(3) and Article 14(1) of Directive 2011/83/EU.
190. Inaccurate address, incomplete delivery details and allocation of responsibility
The Customer must provide the necessary and accurate information required to carry out the agreed delivery.
Where the information provided during the ordering process is incomplete or manifestly inaccurate, the Seller may contact the Customer so that the necessary clarification can be made before shipment.
If delivery does not take place because of inaccurate information provided by the Customer, the relevant consequences are assessed according to the actual cause of the incident and the applicable contractual rules.
The existence of an error in the address does not automatically mean that the Customer assumes every risk of loss of or damage to the goods irrespective of the actions of the Seller and carrier.
Where the problem is connected with incorrect transfer of information by the store's information system or defective performance of the shipment, the business must examine its own contractual responsibility.
If a new shipment is required, the possibility of imposing additional costs is assessed according to the actual cause of the unsuccessful delivery and the lawfully disclosed contractual conditions.
The Seller may not unilaterally impose any additional charge without lawful or contractual basis.
Legal basis: Article 6(1)(g), Articles 18 and 20 of Directive 2011/83/EU, together with the applicable rules of national contract law.
191. Payment dispute, investigation of the financial transaction and retention of evidence
The Customer may dispute a particular payment transaction in accordance with the lawful procedures and applicable terms of the relevant payment service.
The dispute may concern, among other matters, possible unauthorised use of a payment instrument, an incorrect charge, a dispute over the amount or another actual event connected with execution of the financial transaction.
The Seller may collect and retain information necessary to document the particular commercial transaction, including the order, the agreed products, the actual amount paid, the shipping status and lawfully available delivery information.
That information may be used for cooperation with the competent payment-service provider and to support the business's lawful position in a dispute procedure in accordance with the obligations and possibilities provided by the applicable framework.
The existence of a recorded order or successful electronic authentication is not automatically conclusive proof that every disputed transaction was lawfully made or that the Customer acted fraudulently.
Where authorisation or proper execution of a payment transaction is disputed, the specific rules on proof and liability applicable to the relevant payment-service providers apply, and this contractual provision does not alter the mandatory allocation of the burden of proof laid down by law.
The Seller may not regard the submission of a lawful payment dispute as, by itself, malicious or unlawful conduct by the Customer. Likewise, the business retains the ability to document the actual circumstances lawfully and exercise its rights where specific evidence of an unfounded or fraudulent claim arises.
Processing and retention of evidence are carried out in accordance with the applicable personal-data-protection requirements, the actual needs of the particular procedure and the legal obligations of the parties involved.
Legal basis: Articles 71–74 of Directive (EU) 2015/2366 concerning disputes, proof of authorisation and liability for unauthorised payment transactions. Articles 5, 6 and 32 of the GDPR concerning lawful processing and security of personal data.
192. Supplier confirmation before undertaking a major commercial commitment
Before undertaking a significant binding obligation to deliver a large quantity of products to a professional buyer, the Seller may carry out a specific procedure to confirm the actual availability of the goods and the corresponding commercial terms of the supplier.
Confirmation may include the quantity, purchase price, product version, availability time, transport conditions and other parameters that materially affect performance of the transaction.
The Seller may retain the relevant commercial correspondence and evidence documenting the information on the basis of which the particular obligation was undertaken.
The existence of supplier confirmation does not automatically mean that the Seller is released from its own liability if the supplier subsequently fails to perform its obligations.
This procedure is a measure for preventing commercial risk and organising professional transactions and does not create an independent restriction on the buyer's rights.
Legal basis: Applicable national contract law and Articles 30, 33 and 45 of the CISG where the Convention applies to the particular international sale. The requirement for prior supplier confirmation is a contractual and organisational procedure and not a general obligation imposed by the above Articles.
193. Changes to commercial prices and their application to future transactions
The Seller may revise the commercial prices of products offered for sale, taking into account actual supply conditions, operating costs, availability of goods and other lawful commercial factors.
Price changes apply to future transactions in accordance with the information displayed in the online catalogue and during the checkout process.
Publication of a new price does not give the Seller a general right unilaterally to increase the agreed price of a contract already concluded.
Where the transaction has not yet become binding under the actual and lawful process for conclusion of the contract, the consequences of any change in the displayed price are assessed according to the particular stage of the order and the information already communicated to the Customer.
The business must organise catalogue-updating mechanisms in a way that reduces discrepancies between the price shown on the product page, in the electronic cart and in the final payment process.
If a discrepancy is identified, the Seller examines the particular transaction and provides the required information to the Customer without assuming that every subsequent catalogue correction automatically alters a contract already concluded.
Legal basis: Article 6(1)(e) and Article 8(2) of Directive 2011/83/EU concerning price and the assumption of an obligation to pay; Articles 3 and 6 of Directive 93/13/EEC concerning unfair contractual terms.
194. Scheduled maintenance, upgrades and technical interventions
The Seller may carry out, or assign to authorised technical providers, maintenance, upgrade and restoration work on the store's electronic infrastructure where such work is necessary for proper operation, improvement of the services provided or resolution of technical and operational problems.
During such work, access to particular website functions, such as product search, account management or completion of new orders, may be temporarily restricted.
The Seller organises the work in a manner that, as far as reasonably possible, limits the risk of data loss, duplicate order entry, incorrect charges or other malfunctions that could affect transactions.
Where maintenance or technical intervention is found to have caused a specific problem with an existing order, the business examines the available information and applies the appropriate remediation procedure.
Maintenance work does not create a general right unilaterally to cancel contracts or exclude Customers' lawful claims.
Legal basis: Article 32(1) of the GDPR concerning processing security, availability and restoration of access to personal data; Article 8 of Directive 2011/83/EU concerning requirements for distance contracts.
195. Changes in legislation and updating commercial procedures
The business must take account of changes in legislation affecting the marketing, safety, labelling, advertising, online sale and cross-border shipment of the products it makes available.
Such changes may concern the commencement of application of a new regulation, amendment of a national provision, introduction of new obligations for a particular category of goods or application of a lawful restriction on making products available in a particular market.
The Seller organises the store's commercial and technical functions so that it can address changes that genuinely affect its products and transactions.
Where a new mandatory requirement affects the presentation or making available of a particular product, the business examines the necessary modification of the corresponding information, procedures or available ordering options.
The existence of an older legal page or commercial description does not justify continuation of activity in breach of a later binding provision that has entered into application.
Changes to public legal pages must correspond to the actual operation of the store and must not be presented as completed compliance measures where the corresponding technical or organisational procedures have not in fact been implemented.
Legal basis: The applicable provisions of Union and national law from time to time, in particular Regulation (EU) 2023/988, Directive 2011/83/EU and the specific provisions concerning the store's actual product categories.
196. Review of the electronic shopping cart before final submission of the order
Before final submission of the order, the Customer must have the opportunity to review the selected products, corresponding quantities, applicable prices and other information necessary for a proper understanding of the particular transaction.
The checkout process must clearly present the total amount payable, including applicable taxes and additional costs that must be disclosed under the law.
Where the order includes different versions of the same product or several commercial units, the relevant presentation must enable the Customer to determine the actual quantity and characteristics of the goods to be purchased.
The business ensures that any applicable discounts, coupons, shipping costs and additional optional services are displayed in a way that allows the final amount to be checked before the obligation to pay is undertaken.
Where a discrepancy is identified between the electronic cart and the final payment process, the Seller must deal with the incident in accordance with the actual details of the transaction and the applicable information obligations.
The cart-review process does not release the Seller from responsibility for incorrect or misleading information that the Seller itself provides concerning products and material terms of the purchase.
Legal basis: Article 8(2) of Directive 2011/83/EU concerning information that must be presented clearly and prominently immediately before submission of an order that entails an obligation to pay; Articles 10 and 11 of Directive 2000/31/EC.
197. Carrier delay and allocation of contractual obligations
If the transport company does not make delivery within the expected time, the Seller may contact the relevant carrier and use the available procedures to locate and investigate the shipment.
The business may request information concerning the actual location of the parcel, the cause of the delay, the likely delivery date and any other information necessary to manage the particular transaction.
Delay by an independent carrier does not automatically release the Seller from the delivery obligation it has undertaken towards the consumer.
The Seller may not generally require the Customer to deal exclusively with the transport company in order to exercise rights arising from the purchase contract.
Where the Customer has independently engaged a carrier that was not offered as an option by the Seller, the specific allocation of risk provided for by Article 20 of Directive 2011/83/EU is assessed.
The business retains the ability to exercise its own legal or contractual rights against the carrier where the delay is connected with defective performance of the relevant transport service.
Exercise of those rights does not automatically suspend the application of the consumer's mandatory rights arising from failure to deliver on time.
Legal basis: Articles 18 and 20 of Directive 2011/83/EU.
198. Direct cost of returning goods and conditions for charging the consumer
Where the statutory right of withdrawal is exercised, the consumer may bear the direct cost of returning the goods only under the conditions laid down by the applicable legislation.
That charge presupposes, among other things, that the Seller has provided the required prior information concerning the consumer's obligation to bear that cost.
If the Seller has agreed to bear the return costs or has failed to inform the consumer that the consumer must bear them, the corresponding specific provisions of Article 14 of Directive 2011/83/EU apply.
The Seller may not impose a general return-administration fee or another arbitrary financial charge solely because the right of withdrawal has been lawfully exercised.
Where the return is connected with a lack of conformity of the product, treatment of the cost is governed by the specific rules applicable to remedying that lack of conformity.
The business may not pass on to the consumer a cost that the law places on the Seller in providing a statutory remedy for lack of conformity.
Any additional optional commercial return service must be distinguished from obligations imposed by law.
Legal basis: Article 6(1)(i) and Article 14(1) of Directive 2011/83/EU. Articles 13 and 14 of Directive (EU) 2019/771 concerning the free-of-charge remedy of lack of conformity.
199. Backups, restoration of information systems and preservation of data integrity
The Seller organises appropriate procedures for protecting and restoring the information systems used to fulfil orders, manage payments, register products and process personal data.
The business may create backups of necessary data and use appropriate storage, integrity-checking and restoration mechanisms for the relevant systems.
The procedures must be organised according to the nature and seriousness of the relevant risks, taking into account the need to preserve the confidentiality, integrity and availability of personal data.
The business must appropriately assess the ability to restore systems following a technical incident so as to reduce the risk of losing material transaction data.
The existence of backups does not justify indefinite retention of personal data and does not release the Seller from obligations to deal with security incidents.
Legal basis: Article 32(1)(b), (c) and (d) of the GDPR concerning security, restoration capability and regular evaluation of the effectiveness of technical and organisational measures.
200. Products of third-party manufacturers, trademarks and independent resale activity
The online store may offer genuine products of third-party manufacturers and use their corresponding trade names and trademarks to the extent that such use is permitted by the applicable legislation.
Reference to a brand, logo or particular product range is intended to identify and properly present the goods offered for sale and does not, by itself, imply an official partnership, commercial representation, authorised distribution or other contractual relationship with the relevant manufacturer.
The Seller does not acquire rights in third-party trademarks, logos or other protected elements merely as a result of lawfully purchasing or reselling their products.
Likewise, the absence of a direct contractual relationship with a particular manufacturer does not automatically mean that every resale of that manufacturer's genuine product is prohibited. The lawfulness of the particular resale is assessed in accordance with the rules applicable to trademarks, the origin of the goods, their placing on the market and any specific restrictions applicable to the relevant product category.
The business must avoid commercial statements or visual presentations that could create the misleading impression that it is an official partner or authorised representative of a manufacturer where it does not hold that status.
Original photographs, descriptions and other creative material lawfully produced by the business or used under a valid licence are distinct from the trademark rights relating to the products depicted.
Legal basis: Articles 14 and 15 of Regulation (EU) 2017/1001 concerning lawful use of marks for identifying products and exhaustion of trademark rights; Article 6(1)(c) of Directive 2005/29/EC concerning misleading statements of commercial approval or affiliation.