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Refund & Return Policy
Effective Date: 30 September 2025
1. Introduction
This Refund & Return Policy (“Policy”) is issued by Itemare OÜ, registry code 17309345, registered address: Jõe tn 5, Kesklinna linnaosa, Tallinn, 10151, Estonia (“Company”, “we”, “our”). It governs all purchases of digital products, including computer games, activation keys, and digital content made through lootkey.org.
2. Final Sale of Digital Content
All sales of digital content are final once the product key or download link is delivered, accessed, or activated. Digital goods are intangible and cannot be returned after access or activation. Refunds are only possible under the limited circumstances described in this Policy.
3. EU Withdrawal Right and Waiver (Directive 2011/83/EU)
If you are a consumer residing in the European Union, you have the statutory right to withdraw from a digital purchase within 14 days. However, this right does not apply once you have consented to immediate supply of the digital content. At checkout, you will be asked to actively confirm the following waiver:
“I request immediate delivery of the digital content and acknowledge that I lose my 14-day right of withdrawal once the activation key is issued or the download begins.”
4. Refund Eligibility
Refunds may be granted in the following cases:
- The product or activation key was not delivered due to a technical error.
- The activation key provided is non-functional or invalid.
- A duplicate purchase was made accidentally.
Refund requests must be submitted within 14 calendar days of purchase and are subject to verification that the key has not been used or activated.
5. Remedies under Directive 2019/770 (Defective Digital Content)
If digital content is defective or not functioning as described, we will, at our discretion and without undue delay:
- Replace or reissue the activation key;
- Restore access to the product;
- Provide a proportionate price reduction; or
- Issue a full refund if repair or replacement is impossible or disproportionate.
6. PSD2 Chargebacks and Dispute Resolution
Before initiating a chargeback or dispute, you agree to contact our support team at support@lootkey.org to attempt resolution. We cooperate with payment processors and banks under PSD2 dispute mechanisms to investigate unauthorized or disputed transactions. Fraudulent chargebacks or misuse of dispute procedures may result in account restrictions and reporting under AML regulations.
7. Refund Procedure and SLA
To request a refund, contact support@lootkey.org with proof of purchase and a detailed description of the issue. Our team will respond within 3 business days and may require verification that the key has not been activated. Approved refunds will be processed within 14 banking days using the same payment method used for the original purchase.
8. Exclusions
Refunds are not available for:
- Activated or redeemed product keys;
- Successfully downloaded and accessed products;
- Issues caused by incompatibility with your system (hardware, OS, or region restrictions);
- User errors, accidental deletions, or software conflicts beyond our control.
Before purchase, you are responsible for verifying your system meets the product’s minimum requirements.
9. AML and Verification Requirements
To prevent fraud and comply with AMLD6, we may request proof of identity or payment ownership before processing refunds. Failure to provide verification may result in refund denial. Data collected for AML purposes is handled per our Privacy Policy and retained for up to 5 years as required by law.
10. Data Retention and Privacy
We retain refund and transaction records for as long as necessary to comply with tax, accounting, and legal requirements. Personal data processing complies with Regulation (EU) 2016/679 (GDPR) and our Privacy Policy (https://lootkey.org/privacy-policy).
11. Jurisdiction, ODR Platform, and Supervisory Authority
This Policy is governed by the laws of Estonia. Disputes shall be handled under Estonian jurisdiction. EU consumers may also use the EU Online Dispute Resolution (ODR) platform at https://ec.europa.eu/consumers/odr.
Supervisory Authority: Estonian Consumer Protection and Technical Regulatory Authority (TTJA) and Andmekaitse Inspektsioon for data protection matters.
12. Contact Information
For refund inquiries or GDPR-related questions: Itemare OÜ
Email: support@lootkey.org | privacy@lootkey.org
Registered Address: Jõe tn 5, Kesklinna linnaosa, Tallinn, 10151, Estonia
Registry Code: 17309345