Marketplace standards

Verification & compliance

These policies explain how inventory is checked, what is allowed, and how enforcement works on scent.to.

Verification Policy

VERIFICATION POLICY

Scent.to Marketplace

Version 1.0 [Date]

1. INTRODUCTION AND PURPOSE

1.1. This Verification Policy (hereinafter – the "Policy") describes the verification services provided by Scent.to in connection with products offered through the Platform, the scope and limitations of those services, and the rights and obligations of Sellers and Buyers in connection with Verification.

1.2. This Policy forms part of the Platform Policies and should be read together with the Terms and Conditions and any other applicable Platform Policies. Capitalised terms used but not defined in this Policy have the meanings given to them in the Terms and Conditions.

1.3. The purpose of Verification is to support trust and transparency within the marketplace by providing an independent assessment of whether a product physically corresponds to the description provided by the Seller at the time of listing. Verification is not a guarantee of any characteristic of a product beyond its correspondence with the Listing description.

1.4. Scent.to conducts Verification in its capacity as a logistics coordinator and fulfilment service provider handling products on behalf of Sellers. Verification is a component of the Services provided to Sellers and is not an independent service provided to Buyers.

2. WHAT VERIFICATION IS AND IS NOT

2.1. Verification is:

(a) a visual and functional examination of a product conducted at Scent.to's designated facility at a specific point in time;

(b) an assessment of whether the product physically corresponds to the Seller's Listing description, including fill level, condition, packaging and disclosed defects;

(c) a check that mandatory product information is present on the product, including any labelling required under applicable law;

(d) a check that the product does not show visible signs of having been refilled, decanted, altered or transferred into non-original containers;

(e) a check that the product's use-by date or period-after-opening indicator, where visible, has not been exceeded;

(f) a reasonable-efforts assessment of the product's general condition and presentation.

2.2. Verification is not and must not be understood as:

(a) authentication, certification or confirmation of the genuineness, origin or brand legitimacy of a product;

(b) expert appraisal, laboratory analysis, spectrometric testing or any form of scientific examination;

(c) a guarantee that the product is free from manufacturing defects, degradation or changes in scent character attributable to age or storage conditions;

(d) a guarantee of the product's safety, composition, fitness for purpose or compliance with cosmetic product regulations beyond what is visible at the time of examination;

(e) an endorsement or authorisation by any brand owner, rights holder or regulatory authority;

(f) a representation that the product has not deteriorated in ways not detectable by visual inspection.

2.3. Scent.to is not a laboratory, authentication service or brand-authorised inspector. Scent.to does not employ fragrance experts, chemists or brand specialists in connection with the Verification process. The visual and functional nature of Verification defines its scope and its limitations.

2.4. The outcome of Verification does not affect the Seller's responsibility for the accuracy of the Listing or for the confirmations given under the Seller Agreement. Verification is not a substitute for an honest and accurate Listing.

3. THE VERIFICATION PROCESS

3.1. Products submitted for sale through the Platform are routed through Scent.to's designated facility prior to dispatch to the Buyer. Verification is conducted as part of this logistical process.

3.2. Upon receipt of a product at Scent.to's facility, the following steps are carried out:

(a) Receipt and logging — the product is received, recorded and assigned to the relevant Transaction. Inbound condition is noted at receipt.

(b) Visual examination — the product is visually examined against the Seller's Listing, including photographs submitted by the Seller. The examination covers:

— the brand and product identity as displayed on the product and packaging;

— the fill level, assessed against the range stated in the Listing;

— the condition of the bottle, atomiser, cap and any accompanying packaging or accessories;

— the presence of any defects or damage not disclosed in the Listing;

— the integrity of the original packaging and seals, where present.

(c) Regulatory compliance check — the product is checked for the presence of mandatory labelling information required under applicable law, including Regulation (EC) No 1223/2009 on cosmetic products. This includes checking that the product name, ingredient list, manufacturer identification, use-by date or period-after-opening symbol and any required warnings are present and legible.

(d) Condition documentation — photographs of the product are taken at Scent.to's facility and stored in accordance with the Privacy Policy. These records form part of the Transaction record and may be used in connection with dispute resolution.

3.3. Verification is conducted by Scent.to's operational staff. It is a visual and functional process. It does not involve opening sealed products, testing fragrance composition, or any form of physical intervention that would alter the product's condition.

3.4. The duration and depth of Verification may vary depending on the product, its condition and the volume of products being processed at the relevant time. Scent.to conducts Verification on a reasonable-efforts basis.

4. VERIFICATION OUTCOMES

4.1. Following Verification, one of the following outcomes applies:

(a) Approved — the product corresponds to its Listing description and no material discrepancies have been identified. The product proceeds to dispatch to the Buyer.

(b) Discrepancy identified — a material difference between the product and its Listing has been identified. In this case Scent.to shall be entitled to take the measures described in clause 4.2.

(c) Concern identified — Verification has given rise to a reasonable suspicion that the product may be counterfeit, unsafe or otherwise in breach of the Seller's confirmations under the Seller Agreement. In this case the measures described in clause 4.3 apply.

4.2. Where a material discrepancy is identified under clause 4.1(b), Scent.to shall be entitled to:

(a) notify the Seller of the discrepancy and the nature of the difference identified;

(b) request the Seller's confirmation or correction within two (2) business days;

(c) offer the Buyer the option to proceed with the Transaction at a revised condition category and, where applicable, a revised price, subject to the Seller's agreement;

(d) reject the product and return it to the Seller at the Seller's cost, in which case no Commission shall be charged but a handling fee may apply as set out in the Fees and Payments Policy;

(e) cancel the Transaction and arrange for the return of the Buyer's payment in full via the PSP, where the discrepancy is of a nature that a reasonable Buyer would not have proceeded with the Transaction had they been aware of it.

4.3. Where a concern is identified under clause 4.1(c), Scent.to shall be entitled to:

(a) withhold the product and suspend the Transaction pending further review;

(b) withhold the Net Payout pending resolution;

4.4. Verification outcomes are recorded in the Transaction record. Scent.to undertakes to notify the Seller of the outcome within two (2) business days of completion of Verification, except where a concern under clause 4.1(c) has been identified, in which case Scent.to shall notify the Seller as soon as practicable.

4.5. The Buyer shall be notified of the Verification outcome to the extent relevant to the Transaction. Where the product has been approved under clause 4.1(a), no separate notification is required — approval is indicated by the product proceeding to dispatch.

5. PREMIUM VERIFICATION

5.1. Sellers may select the Premium Verification Optional Service at the time of Listing creation or thereafter, as described in the Fees and Payments Policy.

5.2. Premium Verification includes the following in addition to the standard Verification process:

(a) extended photographic documentation of the product, including additional angles and close-up images of relevant condition details;

(b) priority processing — the product is examined ahead of standard Verification queue;

5.3. The "Premium Verified" badge indicates that the product has undergone extended visual examination and documentation in accordance with clause 5.2. It does not indicate, imply or guarantee:

(a) that the product is authentic or genuine within the meaning of any brand owner's standards;

(b) that the product has been examined by a fragrance expert or brand specialist;

(c) any characteristic of the product beyond its correspondence with the Listing description as assessed through visual and functional examination.

5.4. Scent.to undertakes to ensure that all marketing materials, platform interface elements and communications referring to Premium Verification and the "Premium Verified" badge are consistent with the limitations set out in this Section. No language suggesting authentication, genuineness or brand endorsement shall be used in connection with the badge or the Premium Verification service.

5.5. The fee for Premium Verification is set out in the Fees and Payments Policy. The fee is charged only upon completion of a Transaction and is non-refundable once the Verification has been performed.

6. SELLER AND BUYER OBLIGATIONS IN CONNECTION WITH VERIFICATION

6.1. Sellers undertake to:

(a) submit products for Verification in the condition described in the Listing, without modification, cleaning, repackaging or any other alteration between the time of Listing and dispatch to Scent.to's facility;

(b) package products securely for inbound transit in accordance with the shipping guidelines communicated by Scent.to;

(c) not submit any product for Verification that the Seller knows or suspects to be counterfeit, unsafe or otherwise in breach of the confirmations given under the Seller Agreement;

(d) cooperate with Scent.to in connection with any discrepancy or concern identified during Verification, including by providing any additional information or documentation requested within the timeframes specified.

6.2. Buyers acknowledge that:

(a) Verification has been conducted prior to dispatch and that the Verification records, including photographs, form part of the Transaction record available to Scent.to for dispute resolution purposes;

(b) the "Premium Verified" badge, where displayed, indicates extended visual examination only and does not constitute a guarantee of genuineness or authenticity;

(c) Verification does not affect the Buyer's obligation to review the product upon receipt and to raise any dispute within the Inspection Period in accordance with the Returns and Refunds Policy.

7. LIMITATIONS OF LIABILITY

7.1. Scent.to conducts Verification on a reasonable-efforts basis. Scent.to does not warrant that Verification will identify all discrepancies between a product and its Listing, and is not liable for discrepancies that were not and could not reasonably have been identified through visual and functional examination at the time of Verification.

7.2. Scent.to is not liable for characteristics of a product that are not detectable through visual inspection, including but not limited to changes in fragrance composition, internal contamination, microscopic damage or any characteristic that requires scientific testing to identify.

7.3. The limitations in this Section apply to standard Verification and to Premium Verification equally. The extended scope of Premium Verification does not expand Scent.to's liability beyond what is described in this Policy.

7.4. Nothing in this Policy limits or excludes Scent.to's liability for direct physical damage to a product caused by Scent.to's own negligence during handling, which is addressed in Section 6.7 of the Seller Agreement and Section 10.7 of the Terms and Conditions.

7.5. Nothing in this Policy limits or excludes any rights that Users may have under mandatory provisions of applicable law.

8. GENERAL PROVISIONS

8.1. Scent.to shall be entitled to amend this Policy from time to time to reflect changes in its operational processes or applicable law. Any material amendment shall be communicated to Users through the Platform no less than thirty (30) days before its effective date.

8.2. This Policy shall be governed by and construed in accordance with the laws of the Republic of Latvia. Any disputes arising in connection with this Policy shall be subject to the jurisdiction provisions set out in Section 12 of the Terms and Conditions.

8.3. Nothing in this Policy is intended to limit or exclude any rights that Users may have under mandatory provisions of applicable law.

Seller Rules & Prohibited Items

SELLER RULES AND PROHIBITED ITEMS POLICY

Scent.to Marketplace

Version 1.0 [Date]

1. INTRODUCTION

1.1. This Seller Rules and Prohibited Items Policy (hereinafter – the "Policy") sets out the rules applicable to Sellers using the Platform, including the types of products that may and may not be listed, the standards required of Listings, and the conduct expected of Sellers.

1.3. By creating a Listing, the Seller confirms that they have read and understood this Policy and that the product and Listing comply with its requirements. Scent.to shall be entitled to remove Listings, restrict accounts or take other measures where this Policy is not complied with.

2. WHO MAY SELL ON THE PLATFORM

2.1. The Platform is intended exclusively for private individuals selling fragrance products from their personal collections. Selling on the Platform in a professional or commercial capacity is not permitted unless expressly authorised by Scent.to.

2.2. To be eligible to sell, a Seller must:

(a) be at least eighteen (18) years of age;

(b) be acting as a private individual and not in the course of a business or trade;

(d) have the legal right to sell the products under applicable law.

2.3. Sellers who are VAT-registered or who otherwise hold professional trader status in their country of residence must notify Scent.to before creating any Listing and may not use the Platform in a private capacity.

2.4. Indicators that may lead Scent.to to assess a Seller as acting commercially include high listing volume, frequent and systematic selling activity, acquisition of products for the purpose of resale, and patterns inconsistent with selling from a personal collection.

3. WHAT MAY BE LISTED

3.1. Only the following products may be listed on the Platform:

(a) pre-owned or second-hand fragrance products — including eau de parfum, eau de toilette, eau de cologne, parfum and related fragrance products — in their original, unaltered manufacturer packaging;

(b) products that originate from the Seller's personal collection and have been in the Seller's personal possession.

3.2. Products must:

(a) be genuine — corresponding to the brand and product identity stated in the Listing;

(b) be in their original container with the original atomiser, cap and seal intact where applicable;

(d) not have been subjected to any physical or chemical alteration affecting their composition, safety or presentation;

(e) be safe for their intended use — not expired, not contaminated and stored under conditions that would not reasonably be expected to affect their safety or fitness for use;

(f) comply with the minimum price requirement of €60 per Listing.

4. PROHIBITED ITEMS

4.1. The following products must not be listed on the Platform under any circumstances:

Counterfeit and inauthentic products

(a) products that are counterfeit, replica, fake or imitation versions of any brand or product, regardless of how they are described;

(b) products bearing trade marks, logos or branding of a brand owner without the brand owner's authorisation;

Modified and altered products

(d) products that have been refilled — partially or fully — with any substance, whether identical to the original or not;

(e) products that have been decanted from their original container into any other container, whether original-branded or generic;

(f) products that have been transferred into non-original containers, including empty bottles of any brand;

(g) products where the atomiser, spray mechanism or internal components have been replaced, modified or tampered with;

(h) products where the packaging, labelling or safety seals have been removed, damaged or altered in any way that affects the product's identity or traceability.

Unsafe and non-compliant products

(i) products that have exceeded their use-by date or period-after-opening as indicated on the product or packaging;

(j) products that have been stored under conditions likely to have affected their safety, including exposure to extreme temperatures, direct sunlight or contaminants;

(k) products subject to a recall, withdrawal or safety advisory by the manufacturer, a regulatory authority or a market surveillance body;

(l) products that do not carry the mandatory labelling information required under Regulation (EC) No 1223/2009 on cosmetic products, where such labelling was present on the original product.

Unlawfully obtained products

(m) stolen products or products obtained through fraud, misrepresentation or any unlawful means;

(n) products obtained in breach of any contractual restriction on resale imposed by the manufacturer or original retailer, where such restriction is enforceable under applicable law.

Out-of-scope products

(o) products other than fragrance products as defined in clause 3.1, including but not limited to skincare, haircare, candles, diffusers or any other product category not expressly permitted;

(p) gift sets, bundles or multi-item Listings, unless Scent.to has expressly permitted such format.

4.2. The prohibitions in clause 4.1 apply regardless of how a product is described in the Listing. Describing a counterfeit product as a "replica" or a refilled product as "topped up" does not make the Listing compliant.

5. LISTING STANDARDS

5.1. Each Listing must relate to a single, individually identifiable product. Listings for multiple products or unspecified items are not permitted.

5.2. Photographs — each Listing must include photographs of the actual product being sold. The following are required:

(a) at least one photograph of the front of the bottle clearly showing the brand and product name;

(b) at least one photograph of the fill level, taken from the side against a neutral background;

(d) a photograph of the packaging or box, where included.

Photographs must be of the actual product and taken by the Seller. Stock images, manufacturer photographs or images of a different product are not permitted.

5.3. Fill level — fill level must be described using the categories or range indicators available through the Platform's Listing interface. Fill level descriptions must be accurate and must not overstate the remaining volume.

5.4. Condition — condition must be described accurately using the condition categories available on the Platform. The following standards apply:

Condition	Description
New / Unused	Product has never been used. Atomiser has not been pressed. Original packaging intact.
Like New	Used once or twice. No visible signs of use on bottle or packaging.
Very Good	Light use. Minor signs of use. No damage to bottle or atomiser.
Good	Regular use. Visible signs of use. Minor cosmetic imperfections acceptable.
Fair	Heavy use or visible wear. Functional but shows clear signs of use. All defects must be disclosed.

5.5. Defect disclosure — any defects, damage, scratches, staining, label damage, missing components or other issues must be disclosed in the Listing description and shown in photographs. Non-disclosure of a known defect constitutes a material breach of the Seller Agreement.

5.6. Packaging — the Listing must clearly state whether original packaging (box, outer sleeve, gift wrapping) is included. Where packaging is not included, this must be disclosed. Where packaging shows damage, this must be disclosed and photographed.

5.7. Listing language — Listings must be created in the language specified by the Platform. Listings in other languages may be removed without notice.

5.8. Prohibited Listing content — Listings must not contain:

(a) false or misleading statements about the product, its origin, condition or authenticity;

(b) claims that the product is "guaranteed authentic", "100% original" or similar representations that cannot be verified through visual inspection alone;

(d) external links, contact details or content intended to redirect transactions outside the Platform;

(e) content that infringes third-party intellectual property rights, including brand imagery used without authorisation.

6. SELLER CONDUCT

6.1. Sellers must use the Platform honestly and in good faith and must not engage in any conduct that undermines the integrity of the marketplace.

6.2. The following conduct is prohibited:

(a) submitting false or misleading information at any stage of the Listing or Transaction process;

(b) manipulating the Verification process, including by temporarily improving a product's appearance for photography or submission to Scent.to's facility;

(c) attempting to conduct or redirect Transactions outside the Platform, including by sharing contact details with Buyers through Listing descriptions or messaging;

(d) creating multiple accounts to circumvent enforcement measures or Listing limits;

(e) misusing the dispute or returns mechanism, including submitting false or exaggerated claims;

(f) engaging in any form of price manipulation, including artificial price inflation or coordinated pricing with other Sellers;

(g) submitting Listings for products not yet in the Seller's possession.

6.3. Sellers must respond to enquiries from Scent.to in connection with Listings, Transactions or compliance matters within the timeframes requested. Failure to respond may result in suspension of the relevant Listing or account.

7. ENFORCEMENT

7.1. Scent.to monitors Listings and Seller activity for compliance with this Policy. Monitoring may include automated screening and human review.

7.2. Where Scent.to identifies a breach of this Policy, it shall be entitled to take one or more of the following measures proportionate to the nature and severity of the breach. For minor or inadvertent violations — such as inaccuracies in condition description or fill level that do not indicate deliberate misrepresentation — Scent.to will ordinarily request that the Seller amend or correct the Listing before taking further measures.

(a) request that the Seller amend or remove a non-compliant Listing, allowing a reasonable period for correction;

(b) remove a Listing without prior notice where it contains prohibited items as listed in Section 4, including counterfeit products, refilled or decanted products, or products that pose a safety risk;

(c) remove a Listing without prior notice where it contains deliberately false or fraudulent information that could deceive Buyers or cause immediate harm, and where amendment is not an appropriate remedy given the nature of the inaccuracy;

(d) issue a written warning to the Seller's account;

(e) suspend the Seller's ability to create new Listings for a defined period;

(f) suspend or terminate the Seller's account in accordance with Section 13 of the Terms and Conditions;

(g) withhold the Net Payout in accordance with the Seller Agreement where a breach has resulted in financial exposure for Scent.to or a Buyer.

7.3. Where a Listing is removed under clauses 7.2(b) or 7.2(c), Scent.to undertakes to notify the Seller of the reason for removal as soon as practicable. Where a measure under clause 7.2(d), 7.2(e) or 7.2(f) is applied, Scent.to shall notify the Seller in advance except where immediate action is required to prevent harm to Buyers or to comply with applicable law. The Seller may challenge any enforcement measure through the internal complaint handling mechanism described in Section 16 of the Terms and Conditions within fourteen (14) days of notification.

7.4. Sellers who repeatedly engage in deliberate violations of this Policy, or who list prohibited items on more than one occasion, shall be subject to escalating measures up to and including permanent account termination. Minor or inadvertent errors that are promptly corrected upon notification from Scent.to shall not be treated as repeat breaches for the purposes of this clause.

7.5. Where Scent.to has reasonable grounds to believe that a product is counterfeit or that a Seller has engaged in fraud, Scent.to reserves the right to cooperate with competent authorities including by disclosing relevant information in accordance with applicable law.

Notice & Action Policy

NOTICE-AND-ACTION POLICY

Scent.to Marketplace

Version 1.0 [Date]

1. INTRODUCTION AND SCOPE

1.1. This Notice-and-Action Policy (hereinafter – the "Policy") sets out the mechanism through which Users, rights holders and third parties may report content or products on the Platform that they believe to be illegal, and describes how Scent.to processes such reports and communicates its decisions.

1.2. This Policy is established in accordance with Article 16 of Regulation (EU) 2022/2065 on a Single Market for Digital Services (Digital Services Act — "DSA") and applicable EU and Latvian law.

1.3. This Policy forms part of the Platform Policies and should be read together with the Terms and Conditions and any other applicable Platform Policies. Capitalised terms used but not defined in this Policy have the meanings given to them in the Terms and Conditions.

1.4. This Policy applies to notices concerning allegedly illegal content or products on the Platform. It does not apply to disputes between Buyers and Sellers regarding the condition or description of products, which are handled through the Returns and Refunds Policy, or to complaints about decisions taken by Scent.to in relation to content moderation, which are handled through the internal complaint mechanism described in Section 16 of the Terms and Conditions.

2. WHAT MAY BE REPORTED

2.1. Any person may submit a notice to Scent.to where they have reason to believe that a Listing or other content on the Platform contains or constitutes illegal content within the meaning of applicable law.

2.2. Examples of content that may be reported include:

(a) Listings offering counterfeit, replica or inauthentic products in breach of trade mark or intellectual property rights;

(b) Listings offering stolen goods or products obtained through unlawful means;

(d) Listings offering products that are unsafe, dangerous or not compliant with applicable product safety legislation;

(e) Listings offering products the sale of which is prohibited under applicable EU or national law;

(f) other content on the Platform that is illegal under applicable law.

2.3. Notices concerning content that is merely objectionable, inaccurate or in breach of the Platform Policies — but not illegal under applicable law — will be assessed under the Platform's internal moderation procedures rather than this Policy. Scent.to may nonetheless take appropriate action in relation to such content.

3. HOW TO SUBMIT A NOTICE

3.1. Notices must be submitted electronically through the reporting mechanism available on the Platform or by contacting Scent.to at legal@scent.to.

3.2. In order for a notice to be considered sufficiently substantiated, it must include the following information:

(a) the identity and contact details of the person or entity submitting the notice, including name and email address. Notices may be submitted anonymously where the reporter does not wish to be identified to the content provider, but anonymous notices may receive limited follow-up;

(b) a clear identification of the content or product being reported, including the URL or other identifier of the relevant Listing where available;

(c) a description of why the content is believed to be illegal, including a reference to the specific legal provision alleged to be infringed where known;

(d) a statement confirming that the person submitting the notice believes, in good faith, that the information provided is accurate and that the content is illegal.

3.3. Where a notice concerns an alleged infringement of intellectual property rights, the notice should additionally include:

(a) identification of the intellectual property right allegedly infringed, including trade mark registration numbers or other relevant identifiers where available;

(b) confirmation that the person submitting the notice is the rights holder or is authorised to act on behalf of the rights holder.

3.4. Notices that do not contain sufficient information to identify the content in question or to substantiate the allegation of illegality may be declined or result in limited action. Scent.to may request additional information from the person submitting the notice where this would assist in the assessment.

3.5. Submitting a notice does not guarantee that the reported content will be removed. Each notice is assessed individually on its merits.

4. HOW SCENT.TO PROCESSES NOTICES

4.1. Upon receipt of a notice, Scent.to shall:

(a) acknowledge receipt to the person who submitted the notice without undue delay;

(b) assess whether the notice is sufficiently substantiated in accordance with clause 3.2;

(c) where the notice is sufficiently substantiated, assess the reported content against applicable law and the Platform Policies.

4.2. Scent.to shall process notices without undue delay. For notices concerning products that may pose an immediate safety risk, Scent.to shall take interim measures — including suspension of the relevant Listing — as soon as reasonably practicable pending full assessment.

4.3. Following assessment, Scent.to shall take one of the following decisions:

(a) Action — where Scent.to determines that the reported content is illegal or in serious breach of the Platform Policies, it shall take appropriate measures which may include removal or suspension of the Listing, restriction of the relevant Seller's account, withholding of the Net Payout or referral to competent authorities;

(b) No action — where Scent.to determines that the reported content is not illegal and does not warrant removal, it shall take no action in respect of the content on the basis of the notice received.

4.4. Scent.to shall notify:

(a) the person who submitted the notice of the decision taken and the reasons for it, without undue delay following the decision;

(b) the Seller whose Listing is affected by the decision, of the decision taken, the reasons for it, and the available means of redress, without undue delay following the decision, subject to any limitations required by law enforcement considerations.

4.5. Where Scent.to is unable to complete its assessment within fourteen (14) days of receipt of a sufficiently substantiated notice, it shall inform the person who submitted the notice of the delay and provide an estimated timeframe for the decision.

5. TRUSTED FLAGGERS

5.1. Scent.to may designate or cooperate with entities recognised as trusted flaggers under applicable law, including pursuant to DSA Article 22. Notices submitted by trusted flaggers shall be processed as a priority.

5.2. Trusted flagger status does not exempt a notice from the substantiation requirements of clause 3.2, but notices from trusted flaggers will be given appropriate weight in Scent.to's assessment.

6. REDRESS AND APPEALS

6.1. For the person who submitted the notice: where a person disagrees with Scent.to's decision not to take action following a notice, they may submit a complaint through the internal complaint handling mechanism described in Section 16 of the Terms and Conditions or pursue any other remedy available under applicable law, including through competent authorities or courts.

6.2. For the Seller whose Listing is affected: where a Seller disagrees with a decision to remove or suspend their Listing following a notice, they may:

(a) submit a counter-statement through the Platform's internal complaint mechanism within fourteen (14) days of notification of the decision, providing reasons why they believe the decision is incorrect and any supporting evidence;

(b) pursue any other remedy available under applicable law.

6.3. Scent.to undertakes to review counter-statements in good faith and to communicate its determination within fourteen (14) days of receipt. A counter-statement does not automatically result in reinstatement of a removed Listing but will be taken into account in Scent.to's review.

6.4. Where a Listing has been removed and the Seller's counter-statement is upheld following review, Scent.to undertakes to reinstate the Listing promptly and to release any withheld Net Payout subject to any deductions properly applied.

7. MISUSE OF THE NOTICE MECHANISM

7.1. Notices must be submitted in good faith. Submitting a notice that the person knows to be false or misleading, or submitting notices with the intent to harm a competitor or another User, constitutes misuse of this mechanism.

7.2. Scent.to shall be entitled to decline to process notices that are manifestly unfounded, abusive or submitted repeatedly without substantiation. Where misuse is identified, Scent.to may restrict the ability of the relevant person to submit further notices.

7.3. Persons who submit false notices may be liable under applicable law, including for damages caused to Sellers whose Listings are removed as a result.

8. COOPERATION WITH AUTHORITIES

8.1. Where a notice indicates potential criminal activity or serious harm, Scent.to may refer the matter to competent law enforcement or regulatory authorities in accordance with applicable law, in addition to taking any action on the Platform.

8.2. Scent.to shall cooperate with competent authorities in connection with investigations relating to content or products on the Platform as required by applicable law, including under the DSA and applicable product safety legislation.

9. GENERAL PROVISIONS

9.1. Scent.to shall be entitled to amend this Policy from time to time to reflect changes in applicable law or its operational procedures. Any material amendment shall be communicated through the Platform no less than thirty (30) days before its effective date.

9.2. This Policy shall be governed by and construed in accordance with the laws of the Republic of Latvia and applicable EU law.

9.3. Nothing in this Policy limits or excludes any rights available to Users or third parties under mandatory provisions of applicable law.

Product Safety & Compliance

PRODUCT SAFETY AND COMPLIANCE POLICY

Scent.to Marketplace

Version 1.0 [Date]

1. INTRODUCTION AND SCOPE

1.1. This Product Safety and Compliance Policy (hereinafter – the "Policy") describes the product safety framework applicable to the Platform, the obligations of Sellers in relation to product safety, and the measures taken by Scent.to to ensure that products made available through the Platform are safe and compliant with applicable law.

1.3. This Policy applies to all pre-owned fragrance products listed and sold through the Platform. It is established in accordance with Regulation (EU) 2023/988 on general product safety (GPSR), Regulation (EC) No 1223/2009 on cosmetic products, and applicable EU and Latvian law.

2. APPLICABLE LEGAL FRAMEWORK

2.1. The following legislation is directly applicable to the operation of the Platform and the products offered through it:

Regulation (EU) 2023/988 — General Product Safety Regulation (GPSR)

Effective from 13 December 2024, the GPSR establishes a general framework for the safety of non-food consumer products in the EU. It applies to all products placed on or made available on the EU market, including products sold online and through digital marketplaces. The GPSR imposes obligations on economic operators — including manufacturers, importers, distributors, fulfilment service providers and online marketplace operators — throughout the supply chain.

Regulation (EC) No 1223/2009 — Cosmetics Regulation

The Cosmetics Regulation governs the safety, labelling and market surveillance of cosmetic products, including fragrances, placed on the EU market. It imposes specific obligations on distributors in relation to labelling, language requirements and expiry dates.

Regulation (EU) 2022/2065 — Digital Services Act (DSA)

The DSA imposes specific product safety obligations on providers of online marketplaces, including obligations to cooperate with the EU Safety Gate rapid alert system and to take measures against unsafe products.

3. SCENT.TO'S ROLE UNDER APPLICABLE LAW

3.1. Scent.to operates in the following capacities for the purposes of applicable product safety legislation:

(a) Provider of an online marketplace within the meaning of GPSR Article 3(14) and DSA Article 3(i). In this capacity, Scent.to provides the digital infrastructure enabling Sellers to offer products to Buyers.

(b) Fulfilment service provider within the meaning of GPSR Article 3(11), in respect of products that are routed through Scent.to's designated facility for Verification and onward dispatch. In this capacity, Scent.to receives, handles, stores and dispatches products on behalf of Sellers.

3.2. Scent.to does not act as a manufacturer, importer or authorised representative of any fragrance product. Scent.to does not place products on the market in its own name or modify any product.

3.3. The obligations applicable to Scent.to in each capacity are described in Sections 4 and 5 of this Policy.

4. SCENT.TO'S PRODUCT SAFETY OBLIGATIONS

4.1. As provider of an online marketplace, Scent.to undertakes to:

(a) design and maintain the Platform in a manner that enables Sellers to comply with their product safety obligations and provide accurate product safety information to Buyers;

(b) cooperate with the EU Safety Gate rapid alert system operated by the European Commission, including by registering with the Safety Gate portal and processing notifications of unsafe products without undue delay;

(c) designate a single point of contact for communication with competent market surveillance authorities on product safety matters, accessible at legal@scent.to;

(d) take appropriate measures upon becoming aware that a product offered through the Platform is unsafe, including suspension or removal of the relevant Listing and notification of the Seller and, where required, competent authorities;

(e) respond to requests from competent market surveillance authorities without undue delay;

(f) maintain records of product safety incidents and corrective measures taken.

4.2. As fulfilment service provider, Scent.to additionally undertakes to:

(a) not handle products that it knows or has reasonable grounds to believe are unsafe;

(b) maintain traceability records for all products passing through its facility, including the identity of the Seller from whom each product was received and the Buyer to whom it was dispatched, for a period of at least five (5) years;

(c) cooperate with Sellers and competent authorities in connection with product recalls or withdrawals, including by identifying affected products in its possession and taking appropriate corrective measures;

(d) notify the relevant Seller immediately upon identifying a product that may be unsafe or non-compliant, and take interim measures — including withholding the product from dispatch — pending resolution.

4.3. Under the Cosmetics Regulation, Scent.to undertakes, prior to dispatch of each product, to verify that:

(a) mandatory labelling information required under Article 19 of the Cosmetics Regulation is present on the product, including the product name, ingredient list, manufacturer identification, net content, expiry date or period-after-opening indicator, batch number and any required warnings or precautions;

(b) the product's expiry date or period-after-opening indicator, where present and legible, has not been exceeded;

4.4. Scent.to does not open, test, alter or interfere with products in the course of performing its obligations under this Section. These obligations are performed through visual inspection as part of the Verification process described in the Verification Policy.

5. SELLER OBLIGATIONS

5.1. Sellers are the primary responsible parties for the safety and compliance of the products they list and sell through the Platform. Scent.to's obligations as marketplace operator and fulfilment service provider do not diminish the Seller's primary responsibility.

5.2. Each Seller undertakes to:

(a) list only products that are safe for their intended use and that comply with applicable product safety legislation, including the GPSR and the Cosmetics Regulation;

(b) provide accurate and complete information about the product's origin, condition, composition and any relevant safety characteristics in the Listing;

(c) not list products that are subject to a recall, withdrawal or safety advisory by the manufacturer, a regulatory authority or a market surveillance body;

(d) maintain, to the extent reasonably possible, records that enable traceability of the product's origin, including the source from which the product was originally acquired;

(e) notify Scent.to immediately upon becoming aware that a product they have listed or sold through the Platform may be unsafe, recalled or otherwise non-compliant;

(f) cooperate fully with Scent.to and competent authorities in connection with any product safety investigation, including by providing documentation and taking corrective measures as directed.

5.3. The Seller's obligations under this Section are in addition to the confirmations given under Section 4 of the Seller Agreement and the listing requirements set out in the Seller Rules and Prohibited Items Policy.

6. IDENTIFICATION AND RESPONSE TO UNSAFE PRODUCTS

6.1. Scent.to may become aware of a potential product safety concern through one or more of the following channels:

(a) identification during the Verification process at Scent.to's facility;

(b) a notice submitted by a User or third party through the notice-and-action mechanism described in the Notice-and-Action Policy;

(d) a request or notification from a competent market surveillance authority;

(e) a report from a Buyer following receipt of a product.

6.2. Upon becoming aware of a potential product safety concern, Scent.to shall:

(a) immediately suspend the relevant Listing and, where the product is in Scent.to's possession, withhold it from dispatch pending assessment;

(b) notify the relevant Seller of the concern and the measures taken;

(c) assess the concern based on available information, including Verification records, Listing information and any information provided by the Seller or the reporting party;

(d) take appropriate corrective measures based on the outcome of the assessment, as described in clause 6.3.

6.3. Corrective measures available to Scent.to include:

(a) no further action — where the concern is assessed as unfounded following review of available evidence;

(b) Listing amendment — where the concern relates to inaccurate or incomplete product information and can be resolved through correction of the Listing;

(d) product withdrawal — where the product is in Scent.to's possession and is confirmed or reasonably suspected to be unsafe, Scent.to shall not dispatch it and shall arrange for its secure retention pending further instructions from competent authorities or return to the Seller as appropriate;

(e) notification to competent authorities — where the safety concern warrants reporting to market surveillance authorities, including through the EU Safety Gate portal;

(f) Buyer notification — where a product has already been dispatched to a Buyer and is subsequently identified as potentially unsafe, Scent.to shall notify the Buyer and facilitate a return where appropriate.

6.4. Where a product has already been delivered to a Buyer and is subject to a safety concern, Scent.to shall cooperate with the Seller and competent authorities to ensure that the Buyer is informed and that any necessary corrective action is taken.

7. RECALLS AND WITHDRAWALS

7.1. Where a product listed or sold through the Platform is subject to a recall or withdrawal ordered by a manufacturer, regulatory authority or market surveillance body, Scent.to shall:

(a) suspend all active Listings for the affected product without undue delay upon becoming aware of the recall or withdrawal;

(b) identify any units of the affected product currently in Scent.to's possession and quarantine them pending further instructions;

(d) where a recalled product has already been delivered to a Buyer, assist in facilitating the return and refund process to the extent within Scent.to's operational capacity;

(e) report the recall to the EU Safety Gate portal where required by applicable law.

7.2. Sellers are responsible for cooperating fully with any recall or withdrawal affecting their products, including by notifying Scent.to immediately upon becoming aware of a recall and by taking all measures required under applicable law.

8. EU SAFETY GATE

8.1. Scent.to is registered with the EU Safety Gate portal operated by the European Commission in accordance with its obligations as a provider of an online marketplace under GPSR Article 22.

8.2. Scent.to undertakes to process notifications received through the EU Safety Gate portal without undue delay and to take appropriate measures in relation to any unsafe product identified through this channel.

8.3. Where Scent.to is required to report an unsafe product to the EU Safety Gate portal, it shall do so in accordance with the applicable reporting procedures and timelines.

9. COOPERATION WITH COMPETENT AUTHORITIES

9.1. Scent.to shall cooperate with competent market surveillance authorities in Latvia and other EU Member States in connection with product safety matters, including by:

(a) responding to requests for information without undue delay;

(b) providing access to product records, Verification records and traceability information as required;

(d) reporting product safety incidents as required by applicable law.

9.2. The designated point of contact for product safety communications from competent authorities is legal@scent.to.

10. RECORD KEEPING

10.1. Scent.to maintains the following records in connection with its product safety obligations:

(a) Verification records, including photographs and condition assessments, for each product processed through its facility, retained for a minimum of two (2) years from the date of the Transaction;

(b) traceability records identifying the Seller and Buyer for each product, retained for a minimum of five (5) years from the date of the Transaction;

(c) records of product safety incidents and corrective measures taken, retained for a minimum of five (5) years from the date of the incident.

10.2. Records are maintained in accordance with applicable data protection law as described in the Privacy Policy.

11. GENERAL PROVISIONS

11.1. Scent.to shall be entitled to amend this Policy from time to time to reflect changes in applicable product safety legislation or its operational procedures. Any material amendment shall be communicated through the Platform no less than thirty (30) days before its effective date.

11.2. This Policy shall be governed by and construed in accordance with the laws of the Republic of Latvia and applicable EU law, including the GPSR and the Cosmetics Regulation.

11.3. Nothing in this Policy limits or excludes any rights that Users may have under mandatory provisions of applicable law.