Moderation Policy

This Moderation Policy (“Policy”) describes how KORDIA fosters a safer environment for its users, how inappropriate content and behavior can be reported, the moderation decision-making process and its reasoning, as well as the means users can use to contest such decisions through internal complaint mechanisms and other available remedies.

This Policy should be read in conjunction with the Terms and Conditions, the Privacy and Cookies Policy, the Right to Information, and the Community Guidelines (collectively, the “Platform Policies”).

Where applicable, KORDIA will strictly comply with Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 (“Digital Services Act”/“DSA”), particularly regarding mechanisms for notification of illegal content, due diligence obligations, transparency, and complaint mechanisms.

This Policy applies to all Platform Users, to content and interactions shared through the Platform, and to reports submitted by Users and third parties regarding content or behavior on the Platform.

KORDIA monitors compliance with Platform Policies and applicable law. In the context of a Platform that contains an internal chat, public profiles, and reviews, the most frequent situations that trigger moderation include potential forms of harassment and threats to integrity, hate speech, scam and fraud attempts, spam, unauthorized disclosure of personal data (“doxxing”), review manipulation, content that violates copyright or image rights, and attempts to circumvent the payment/Escrow mechanism when prohibited by Platform Policies.

When KORDIA diligently determines that Content is illegal or violates Platform Policies, it may adopt one or more measures it deems appropriate and proportional. These measures may affect the Content itself, namely removal, blocking access, or restricting visibility when technically feasible, or the profile and functionalities themselves, essentially through warnings, feature limitations (chat, quote requests, bookings), temporary suspension, or permanent termination in severe or repeat cases.

The determination of the appropriate and proportional measure takes into account the severity, potential harm, nature of the content, context and intent, any prior history, and sustained indicators of coordinated abuse, fraud, or manipulation.

KORDIA provides digital channels for reporting transgressive content or behavior, namely through a dedicated email address. To enable swift and effective assessment, the report should include, whenever possible, the name and email address of the reporter, a good faith statement confirming that the information and allegations presented are accurate and complete, identification of the content (link, ID, or screenshot), identification of the targeted profile, the nature of the content or behavior, a detailed description, and relevant context.

When the report concerns alleged Illegal Content, it should indicate, to the extent possible, the reason why the reporter considers the content illegal. KORDIA will analyze reports diligently and impartially. As soon as possible, it will acknowledge receipt and inform the reporter of the outcome, respecting the limits imposed by privacy, security, and applicable legal obligations.

KORDIA will prioritize situations involving imminent risk of serious harm, scam or fraud attempts, systematic harassment and abuse, and large-scale spam or manipulation. Reports will be handled in order of priority and operational capacity, without prejudice to full application of the rules in force.

The Platform does not admit, nor is it intended for, minors under 18 years of age. When there are credible indications of Platform use by a minor or content involving risks related to minors, KORDIA may adopt child protection measures and, when legally required, cooperate with competent authorities.

Moderation decisions are, as a rule, made by humans, based on Platform Policies and context. KORDIA may use technical screening tools; however, it does not intend to use automation as a final decision mechanism without human intervention or supervision.

When KORDIA adopts a relevant moderation measure regarding specific Content or a profile, it will seek to notify the affected User and, where applicable and permitted by law, provide the reasoning for the measure applied, indicating the basis, essential facts, rules applied, and available appeal means. KORDIA may limit the detail of reasoning when necessary to comply with legal obligations, prevent abuse of moderation mechanisms, protect reporters, and preserve the integrity of the investigation.

The User may file an appeal regarding applied measures, such as content removal, feature restriction, suspension, or account termination. The appeal must allow identification of the decision, state the grounds, and provide context by attaching evidence deemed relevant.

KORDIA will evaluate appeals diligently and non-arbitrarily and, whenever possible, will ensure the review is conducted by a person other than the initial decision-maker. The appeal decision may confirm, revoke, or adjust the applied measure accordingly. Where applicable, the internal appeal may be filed within a minimum period of six (6) months from the date the User is notified of the decision.

Where applicable, under the DSA, certified out-of-court dispute resolution mechanisms exist for disputes relating to content moderation, without prejudice to the right to resort to judicial instances and other legal avenues.

Manifestly false, abusive, or bad faith reports and appeals may lead to the application of proportional and appropriate measures, namely restrictions on access to channels, warnings, or other applicable restrictions.

KORDIA may cooperate with competent authorities whenever legally required, namely through compliance with duly reasoned and valid orders or requests under applicable law.

KORDIA maintains the operational records necessary to handle reports and appeals, improve consistency, and comply with applicable legal obligations.

The processing of personal data associated with reports, moderation, and appeals is described in the Privacy and Cookies Policy. KORDIA collects and uses only what is strictly necessary for security, legal compliance, and operation of the reporting and appeal mechanisms.

KORDIA may update this Policy to reflect legal, operational, or security changes.