Content Moderation and Notice-and-Action Policy

1. Introduction and legal framework

This policy governs the Operator's procedure for moderating user content (tips, photographs, comments, messages) in accordance with Regulation (EU) 2022/2065 on a Single Market for Digital Services (the "DSA"), Act No. 480/2004 Coll., on certain information society services, and Directive 2001/29/EC (copyright).

The Operator is an intermediary provider of hosting services within the meaning of Article 3(g) of the DSA and at the same time an online platform within the meaning of Article 3(i) of the DSA. The Platform is not a very large online platform (VLOP) under Article 33 of the DSA.

2. Single Point of Contact

• For users: [email protected] (Czech, English).
• For public authorities and trusted flaggers: [email protected] (Czech, English).

3. Prohibited content

• Content infringing copyright and personality rights.
• False information about a property, misleading advertising.
• Hate speech, discrimination, incitement to violence.
• Fraudulent offers, phishing, malware.
• Content or business activity breaching international sanctions (in particular Regulation (EU) No 269/2014 and 833/2014 and the EU/UN sanctions lists).
• Personal data of third parties without consent.
• Content contrary to good morals or public order.

4. Notice-and-action — how to report content

Anyone (a user as well as a third party) may report content that violates the law or this policy. The notice should contain the information required by Article 16(2) of the DSA:

• A sufficiently substantiated explanation of why the content is illegal.
• A precise identification of the content — link (URL), tip ID, time.
• Identification of the notifier (name, e-mail) — except for notices concerning child sexual abuse and terrorist content, where anonymity is guaranteed.
• A statement by the notifier confirming their good faith and the accuracy of the information.

Send notices to:

5. Assessment procedure

• Confirmation of receipt of the notice — without undue delay, usually within 24 hours.
• Assessment — in a timely, objective, free-of-charge, diligent and non-discriminatory manner (Article 16(6) DSA).
• Decision — usually within 7 calendar days. For serious and manifestly illegal content (CSAM, direct threat), without delay.
• Communication of the decision to both the notifier and the content provider, with a statement of reasons (Article 17 DSA).

6. Measures against content and accounts

The Operator may apply, among others:

• Removal or disabling of access to content.
• Restriction of visibility (so-called downranking).
• Warning to the user, temporary restriction of the account.
• Suspension or termination of the account in the event of repeated violations.
• Suspension of the processing of manifestly unfounded notices (Article 23 DSA).

7. Statement of reasons and right of appeal

A user whose content has been affected will receive a clear and specific statement of reasons (Article 17 DSA). The user may appeal against the decision:

• Internal appeal — directly from the statement of reasons (link to the appeal form) or by e-mail to [email protected] within 6 months of the decision. The review is carried out by a person other than the one who made the original decision.
• Out-of-court dispute settlement under Article 21 of the DSA before a certified body of the user's Member State.
• Judicial review under the general rules.

8. Transparency

In accordance with Article 15 of the DSA, after the expiry of the first full calendar year of the Platform's operation, the Operator will annually publish a content moderation report (number of notices received, number of items of content removed, median handling time, number of appeals and their outcomes). The report is published on the Transparency Reports page no later than the end of the first quarter of the following year.

9. Cooperation with authorities

The Operator cooperates with the Digital Services Coordinator (in the Czech Republic, the Czech Telecommunication Office) and with other law enforcement authorities to the extent provided by law. It responds to requests under Articles 9 and 10 of the DSA without undue delay.