Content moderation policy and notice-and-action

1. Introduction and legal framework

This policy governs the Operator's approach to 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 hosting provider within the meaning of Art. 3(g) of the DSA. The Platform is not a very large online platform (VLOP) within the meaning of Art. 33 of the DSA.

2. Single Point of Contact

• For users: podpora@flipking.cz (Czech, English).
• For public authorities and trusted flaggers: privacy@flipking.cz (Czech, English).

3. Prohibited content

• Content infringing copyright and personality rights.
• False information about real estate, misleading advertising.
• Hate speech, discrimination, incitement to violence.
• Fraudulent offers, phishing, malware.
• Content relating to persons on sanctions lists (EU, UN, OFAC).
• Personal data of third parties without their consent.
• Content contrary to public morals or public order.

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

Anyone (user or third party) may report content that violates the law or these policies. A notice should contain the information set out in Art. 16(2) of the DSA:

• A sufficiently precise explanation of why the content is unlawful.
• Precise identification of the content — link (URL), tip ID, time.
• Identification of the notifier (name, e-mail) — except for notices relating to child sexual abuse, where anonymity is guaranteed.
• A declaration of the notifier's good faith and the truthfulness of the information.

Send notices to:

5. Assessment procedure

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

6. Measures against content and accounts

The Operator may apply, inter alia:

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

7. Statement of reasons and right of appeal

A user whose content is affected will receive a clear and specific statement of reasons (Art. 17 DSA). The decision may be appealed by:

• Internal appeal — by e-mail to podpora@flipking.cz within 6 months of the decision. The review is carried out by a person other than the one who took the original decision.
• Out-of-court dispute resolution under Art. 21 DSA at a certified body of the user's Member State.
• Judicial review under general rules.

8. Transparency

In accordance with Art. 15 DSA, after the first full calendar year of operation of the Platform, the Operator will publish an annual content moderation report (number of notices received, number of content items removed, average handling time, number of appeals and their outcomes). The report is published in the Legal documents section by 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 — ČTÚ) and with other law-enforcement authorities to the extent required by law. It responds without undue delay to requests under Arts. 9 and 10 of the DSA.