EU/NL baseline – internationally applied where lawful – stricter mandatory local consumer protection prevails

Effective date: 27 March 2026
Last updated: 27 March 2026

This consolidated document integrates the key trader information, Terms of Service, Shipping Policy, Returns & Refund Policy, Privacy Policy, Cookie Policy, and Legal Notice & Governing Law and Dispute Resolution for the Sanctum Deo website and webshop.

Structure

• Part 0 - Contact / Key trader information

• Part I - Terms of Service

• Part II - Shipping Policy

• Part III - Returns & Refund Policy

• Part IV - Privacy Policy

• Part V - Cookie Policy

• Part VI - Legal Notice & Governing Law and Dispute Resolution

Part 0 - Contact / Key trader information

This Part 0 is drafted in accordance with Directive 2000/31/EC (E-Commerce Directive), Directive 2011/83/EU (Consumer Rights Directive), and the relevant mandatory provisions of Dutch law, including Book 6 of the Dutch Civil Code, as applicable.

0.1 Trader identity and core statutory disclosures

The trader operating this website and webshop is identified as follows:

0.2 Specialised contact routes and use of Part 0 information

Unless this document clearly states a more specialised contact route for a specific process, the trader details in section 0.1 must be treated as the default identification and contact details for the website and webshop. Any returns-specific, privacy-specific, or complaints-specific contact route supplements section 0.1 and does not replace the trader-identification information that must remain easily accessible to consumers and regulators.

If a telephone number, returns address, VAT number, or registration number is not legally required for a specific trader set-up, the trader should still avoid presenting incomplete or misleading business information. Where mandatory local law requires additional disclosures, those disclosures apply in addition to this document.

Part I - Terms of Service

This Part I is drafted in accordance with Directive 2011/83/EU (Consumer Rights Directive), Directive 93/13/EEC (Unfair Terms Directive), Directive 2005/29/EC (Unfair Commercial Practices Directive), Directive 2000/31/EC (E-Commerce Directive), Directive (EU) 2019/771, and the relevant provisions of Books 3, 6, and 7 of the Dutch Civil Code, as applicable.

I.1 Scope of the Services and acceptance of these Terms

These Terms of Service govern access to and use of the Sanctum Deo website, the placing of orders through the webshop, and related customer interactions before, during, and after checkout. By using the website or placing an order, the customer agrees that these Terms form part of the contractual and pre-contractual information framework, subject always to mandatory law.

I.2 Contract formation and order acceptance

A contract is ordinarily formed when Sanctum Deo accepts the customer’s order and confirms it through the website, checkout flow, order-confirmation message, or another clear acceptance mechanism. Sanctum Deo may refuse or cancel an order before dispatch where reasonably necessary for stock, pricing, compliance, anti-fraud, sanctions, payment, or other lawful operational reasons.

I.3 Product information, pricing displays, and availability

Product descriptions, imagery, sizing information, stock indications, dispatch estimates, and promotional statements are intended to be accurate and fair, but obvious errors and manifest mistakes do not bind Sanctum Deo. Images may vary slightly from the delivered goods because of screen settings, production tolerances, and proportionate product updates, provided the goods remain materially consistent with the contract and mandatory law.

I.4 Customer obligations and prohibited use

The customer must provide accurate billing, delivery, and contact information, use the website lawfully, and refrain from fraudulent, abusive, infringing, or technically harmful conduct. Unauthorised interference with the website, attempts to bypass checkout or security functions, resale in breach of law, or misuse of promotional offers may justify account, order, or access restrictions.

I.5 Intellectual property and website content

All intellectual-property rights in the website, brand assets, logos, copy, product photography, design materials, and related content remain with Sanctum Deo or its licensors unless mandatory law provides otherwise. No licence is granted beyond the limited right to view the website and place lawful consumer purchases. Reproduction, commercial reuse, scraping, or redistribution without consent is prohibited except where mandatory law permits it.

I.6 Prices, payment, delivery baseline, statutory remedies, and liability

Unless clearly stated otherwise, prices shown on the website are displayed in EUR and include VAT where mandatory consumer law requires VAT-inclusive pricing. Shipping charges, duties, taxes, or other charges that cannot reasonably be calculated in advance may be disclosed separately in accordance with applicable law. Payment is due at checkout through the payment methods made available. Nothing in these Terms excludes statutory consumer remedies for late delivery, non-delivery, lack of conformity, misleading information, invalid unfair terms, or non-excludable liability. Any limitation of liability must be read narrowly and will never apply where exclusion is not permitted by law.

Part II - Shipping Policy

This Part II is drafted in accordance with Directive 2011/83/EU (Consumer Rights Directive), Directive (EU) 2019/771, and the relevant mandatory provisions of Books 6 and 7 of the Dutch Civil Code concerning delivery, risk transfer, performance, and consumer sales, as applicable.

II.1 Shipping scope, destinations, and methods

This Part II applies to shipment and delivery of physical goods ordered through the Sanctum Deo webshop. Available destinations, carriers, shipping methods, dispatch windows, and checkout delivery options may vary by product, stock location, destination, operational constraints, and legal restrictions.

II.2 Processing times and dispatch

Any processing time or dispatch estimate shown on the website or at checkout is indicative unless Sanctum Deo expressly guarantees a specific dispatch deadline. Orders may be delayed for stock verification, fraud screening, payment review, customs documentation, force majeure, peak-period volumes, or other reasonable operational causes.

II.3 Delivery estimates and delivery baseline

Delivery estimates are not guaranteed transit commitments unless expressly stated otherwise. For consumer contracts, goods must nevertheless be delivered within the period required by mandatory law or, if no period has been agreed, within the statutory default period applicable to the contract.

II.4 Shipping charges, duties, taxes, and customs

Shipping charges are shown at checkout or otherwise communicated before order completion where legally required. For international shipments, customs duties, import taxes, brokerage fees, and local clearance costs may apply depending on destination and shipping method, unless the website expressly states that such costs are included.

II.5 Address accuracy and failed delivery

The customer must provide a complete and deliverable address and monitor reasonable delivery communications where available. Sanctum Deo is not responsible for delay, non-delivery, or additional costs caused by an inaccurate, incomplete, or inaccessible address supplied by the customer, subject always to non-excludable consumer protections.

II.6 Transfer of risk

For consumers, the risk of loss or damage ordinarily passes when the consumer, or a third party indicated by the consumer other than the carrier, physically receives the goods, unless mandatory law provides otherwise. For non-consumer transactions, risk may pass earlier to the extent permitted by the applicable contract and governing law.

II.7 Lost, delayed, misdelivered, or damaged parcels

If a parcel is lost, materially delayed, misdelivered, or arrives visibly damaged, the customer should notify Sanctum Deo without undue delay and provide reasonable supporting information so that carrier, insurance, and customer-service steps can be started. This operational procedure does not limit statutory consumer rights relating to delivery failure or lack of conformity.

II.8 Legal restrictions, sanctions, and shipping holds

Sanctum Deo may suspend, refuse, or cancel shipment where reasonably necessary to comply with sanctions law, export controls, anti-fraud obligations, customs restrictions, unsafe delivery circumstances, or other legal or compliance requirements. Where an order cannot lawfully be fulfilled, Sanctum Deo will act in accordance with applicable law regarding cancellation and reimbursement.

Part III - Returns & Refund Policy

This Part III is drafted in accordance with Directive 2011/83/EU (including the withdrawal framework and Annex I(B), where applicable), Directive (EU) 2019/771, and the relevant mandatory provisions of Books 6 and 7 of the Dutch Civil Code concerning withdrawal, refunds, delivery, conformity, and consumer remedies.

III.1 Standard withdrawal right for consumer distance sales

As a contractual baseline for consumer distance sales of eligible physical goods, Sanctum Deo offers a 14-day withdrawal period counting from the day on which the consumer, or a third party indicated by the consumer other than the carrier, acquires physical possession of the goods, unless mandatory law grants a longer or otherwise more protective period.

III.2 How withdrawal must be exercised and preferred submission route

To exercise the withdrawal right, the consumer must send an unambiguous statement before the withdrawal period expires. Sanctum Deo strongly recommends that withdrawal and return requests are submitted through the online return portal made available on the website, as this is the fastest and most efficient processing route.

Use of the online return portal is recommended but not legally mandatory unless applicable law clearly permits such a requirement. Consumers who do not wish to use the online return portal may instead submit their withdrawal or return request by email using the return form or another clear written statement sent to admin@sanctumdeo.com before the applicable deadline expires.

Where a return or withdrawal request is submitted outside the online return portal, Sanctum Deo may require reasonable identifying information, such as the order number, order date, the goods concerned, the name used for the order, and the email address or other contact details linked to the order, to identify the relevant contract and process the request. The absence of an order number or other internal reference will not invalidate a request that is otherwise sent in time and clearly identifies the order and the consumer’s intention.

Requests submitted through the online return portal will ordinarily be processed more quickly. Requests submitted by email or by a manually completed return form may be subject to slower handling, longer verification time, and slower operational processing because they require additional manual review. This operational difference does not affect the consumer’s statutory rights or the legal validity of a timely withdrawal notice.

III.3 Return timing, return condition, and diminished value

After valid withdrawal, the consumer must send back the goods without undue delay and no later than 14 days after communicating the withdrawal, unless mandatory law grants more favourable treatment. The consumer is only liable for any diminished value resulting from handling beyond what is necessary to establish the nature, characteristics, and functioning of the goods.

III.4 Refund timing, method, and permissible deductions

Sanctum Deo will reimburse all payments received from the consumer for the withdrawn goods, including the basic outbound delivery costs where mandatory law requires reimbursement of those costs. Refunds will be made without undue delay and, in any event, within the mandatory legal period after withdrawal, using the original payment method unless the consumer expressly agrees otherwise. Sanctum Deo may withhold reimbursement until the returned goods are received or the consumer supplies adequate proof of return, whichever occurs first where applicable law permits this.

III.5 Exclusions from the withdrawal right

The withdrawal right does not apply where mandatory law recognises a valid exception, including for clearly personalised or made-to-order goods, sealed goods not suitable for return for health or hygiene reasons once unsealed after delivery, or other categories lawfully excluded from withdrawal. Any exception must be interpreted narrowly and only where the legal requirements for that exception are actually met.

III.6 Non-conforming goods and statutory remedies outside withdrawal

This operational returns process does not replace statutory remedies for non-conforming goods. Where the goods are defective, incomplete, incorrect, damaged on arrival, or otherwise lack conformity, the consumer may also rely on applicable statutory remedies such as repair, replacement, price reduction, rescission, or damages, depending on the governing mandatory law.

III.7 Operational return process, refused deliveries, and model withdrawal form

Unless Sanctum Deo expressly agrees otherwise, returned goods should be sent to the return address communicated by Sanctum Deo for the relevant return. Refused deliveries, uncollected parcels, or chargebacks are not a substitute for the ordinary complaint or withdrawal process. If a parcel is refused or uncollected, Sanctum Deo may deduct direct and legally chargeable costs to the extent applicable law permits.

III.7A Preferred operational return route

For the orderly and timely handling of returns, Sanctum Deo requests that customers use the online return portal as the primary return channel wherever available. The online return portal is intended to reduce errors, speed up verification, and improve return tracking.

If a customer instead uses email or another manual route to initiate a return, Sanctum Deo will still process the request where legally valid, but the customer acknowledges that manual processing may take longer than portal-based processing. Any such delay relates only to operational handling and does not reduce or restrict any mandatory statutory consumer protection.

III.8 Model withdrawal form

 

Part IV - Privacy Policy

This Part IV is drafted in accordance with Regulation (EU) 2016/679 (GDPR / AVG), the Dutch GDPR Implementation Act (UAVG), and any other applicable mandatory Dutch or European data-protection rules.

IV.1 Controller status and scope of this Privacy Policy

Sanctum Deo acts as controller for the personal data processed in connection with the website, webshop, customer service, order management, payment support, fraud prevention, legal compliance, and marketing activities to the extent it determines the purposes and means of processing.

IV.2 Categories of personal data and processing purposes

Depending on the interaction, personal data may include identity and contact details, billing and shipping details, order and refund history, transaction references, communications content, device and website-use data, and limited fraud-prevention or risk data. These categories are processed to operate the website and webshop, perform and administer contracts, communicate with customers, handle returns and complaints, prevent abuse, comply with legal obligations, and improve legitimate business operations.

IV.3 Legal bases for processing

The principal legal bases are performance of a contract or steps taken at the request of the data subject prior to entering into a contract, compliance with legal obligations, legitimate interests that are not overridden by the data subject’s interests or fundamental rights, and consent where consent is required by law. Where consent is relied on, it may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

IV.4 Relationship with the Cookie Policy

Information about cookies and similar technologies used on the website is set out in Part V (Cookie Policy). Where applicable law requires prior consent for non-essential cookies or tracking technologies, those technologies will only be placed or activated where and to the extent valid consent has been obtained. Strictly necessary cookies may be used without prior consent where permitted by applicable law.

IV.5 Recipients, processors, and service providers

Sanctum Deo may share personal data with processors and service providers involved in hosting, ecommerce infrastructure, payment processing, logistics, customer support, analytics, security, compliance, and professional advisory services, but only to the extent reasonably necessary and subject to appropriate contractual or legal safeguards.

IV.6 Retention periods

Personal data is retained no longer than necessary for the purposes for which it was collected, except where longer retention is required or permitted by tax law, accounting law, limitation periods, fraud-prevention needs, dispute handling, or other legal obligations. Retention periods should therefore be assessed by reference to the category of data and the legal or operational purpose concerned.

IV.7 International data transfers

If personal data is transferred outside the European Economic Area, Sanctum Deo will use a transfer mechanism recognised by applicable law, such as an adequacy decision, Standard Contractual Clauses, or another permitted safeguard, together with supplementary measures where required.

IV.8 Data subject rights

Subject to the conditions and limitations of applicable law, data subjects may request access, rectification, erasure, restriction of processing, data portability, and objection to certain processing, and may withdraw consent where consent is the legal basis. Data subjects also have the right to lodge a complaint with a competent supervisory authority, including the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) where relevant.

IV.9 Security, personal data breaches, and complaints handling

Sanctum Deo must take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access. Where a personal data breach occurs, Sanctum Deo will assess whether notification to the competent supervisory authority or affected data subjects is required under applicable law. 

Part V - Cookie Policy

This Part V is drafted in accordance with Directive 2002/58/EC as amended (ePrivacy rules), Regulation (EU) 2016/679 (GDPR / AVG), the Dutch Telecommunications Act, the Dutch GDPR Implementation Act (UAVG), and any other applicable mandatory Dutch or European rules governing cookies, trackers, and similar technologies.

V.1 Scope and relationship with the Privacy Policy

This Part V explains how Sanctum Deo uses cookies and similar technologies on its website and webshop. It should be read together with Part IV (Privacy Policy) and any consent preferences made available through the cookie banner or preference centre.

V.2 What cookies and similar technologies are

Cookies are small text files or similar technologies that are stored on or accessed from a user’s device when visiting a website. They may be used to make the website function properly, remember preferences, maintain shopping-cart sessions, measure website performance, improve security, and, where permitted, support analytics, marketing, and personalisation.

V.3 Categories of cookies that may be used

Sanctum Deo may use the following categories of cookies or similar technologies:

(a) Strictly necessary cookies. These cookies are necessary for the operation, security, and core functionality of the website and webshop, including cart continuity, checkout flow, fraud prevention, load balancing, security controls, and similar essential functions. Where permitted by law, these cookies do not require prior consent.

(b) Preference or functional cookies. These cookies remember user choices or convenience settings, such as language, region, or display preferences. Where these cookies are not strictly necessary under applicable law, they will only be used on the basis required by that law.

(c) Analytics cookies. These cookies help Sanctum Deo understand how visitors use the website so that performance, usability, and content can be improved. Where analytics cookies are exempt under applicable law, they may be used without prior consent only within the limits of that exemption. Where prior consent is required, they will only be activated after valid consent has been obtained.

(d) Marketing, advertising, and tracking cookies. These cookies or similar technologies may be used to measure campaign effectiveness, personalise content or advertising, build audiences, or track browsing behaviour across time or across websites. These technologies will only be used where and to the extent valid prior consent has been obtained.

V.4 Legal basis and consent

Where a cookie or similar technology is strictly necessary for the transmission of communications or for providing a service explicitly requested by the user, Sanctum Deo may use it without prior consent where lawful. Where consent is required for non-essential cookies or tracking technologies, Sanctum Deo will request that consent before placing or activating them.

Consent may be refused or withdrawn at any time through the cookie settings, consent banner, browser settings where applicable, or other means made available on the website. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

V.5 Third-party providers

The website may use third-party tools or integrations for ecommerce infrastructure, analytics, payments, security, embedded content, marketing, or similar operational purposes. Where such third parties place or read non-essential cookies or similar technologies, those technologies will be subject to the applicable consent requirements and transparency obligations.

V.6 Retention and duration

Some cookies are session-based and expire automatically when the browser session ends. Others remain on the device for a longer period, depending on their purpose and settings. Specific retention periods may vary by provider, cookie type, and technical necessity.

V.7 Managing cookies

Users can manage cookie preferences through the website’s cookie settings where available and may also restrict or delete cookies through their browser settings. Blocking strictly necessary cookies may affect the operation of the website or checkout process.

V.8 Updates and contact

Sanctum Deo may update this Cookie Policy from time to time to reflect legal, technical, or operational changes. The latest version will be made available on the website. Questions about cookies or data protection may be sent to admin@sanctumdeo.com. 

Part VI - Legal Notice & Governing Law and Dispute Resolution

This Part VI is drafted in accordance with Directive 2000/31/EC (E-Commerce Directive), Directive 2011/83/EU (Consumer Rights Directive), Directive 93/13/EEC (Unfair Terms Directive), Directive 2005/29/EC (Unfair Commercial Practices Directive), Directive 2013/11/EU (ADR Directive), Regulation (EC) No 593/2008 (Rome I), Regulation (EU) No 1215/2012 (Brussels I Recast), and the relevant mandatory provisions of Dutch private law and Dutch procedural law, as applicable.

VI.1 Legal notice and status of this consolidated document

This document functions as the consolidated policy framework for the Sanctum Deo website and webshop. It should be read together with the website disclosures, checkout statements, product-page information, order confirmations, and any other legally required pre-contractual or post-contractual notices that are properly presented to the customer.

VI.2 Hierarchy of provisions and subject-matter allocation

Part-specific rules prevail for their own subject matter. Part II governs shipment and delivery operations, Part III governs the operational return and refund process, Part IV governs personal-data processing, and Part V governs cookies and similar technologies. Part I applies generally to website use and contract formation. Part 0 supplies the core trader-identification data. This Part VI governs interpretation, legal notice, governing law, and dispute-resolution rules.

VI.3 Mandatory rights and interpretation

Nothing in this document excludes, waives, or limits any right or remedy that cannot lawfully be excluded, including statutory consumer rights, data-protection rights, transparency requirements, and any mandatory remedies arising under applicable law. This document must therefore be interpreted consistently with mandatory EU law, Dutch law where applicable, and any stricter local mandatory consumer-protection rules that apply in the customer’s jurisdiction.

VI.4 Governing law

Unless mandatory law requires otherwise, this document and any contractual or non-contractual dispute arising out of or in connection with the website or a sale through the webshop are governed by Dutch law.

Where the customer is a consumer residing outside the Netherlands, this choice of Dutch law does not deprive that consumer of the protection of mandatory provisions of the law of the country of the consumer’s habitual residence, or of any other stricter mandatory consumer-protection rules that apply under applicable law.

VI.5 Jurisdiction and consumer forum rights

Where mandatory law permits, disputes may be submitted to the competent courts of the Netherlands. However, nothing in this document requires a consumer to bring or defend proceedings only before the Dutch courts where mandatory jurisdiction rules grant the consumer the right to sue or be sued in the courts of the consumer’s own domicile or another protected forum.

VI.6 Complaints handling, ADR, and the end of the EU ODR platform

Before formal proceedings are started, the customer is encouraged to contact Sanctum Deo first so that the complaint can be reviewed and, where possible, resolved informally. Where applicable law requires information about ADR entities or procedures, Sanctum Deo will provide that information in the legally required manner. The former EU Online Dispute Resolution (ODR) platform has been discontinued and should not be presented as an active complaint channel.