Notice and Action

1.1 Under Articles 11 and 12 of Regulation (EU) 2022/2065 (the Digital Services Act), we designate a single electronic point of contact for Member State authorities, the Commission, the European Board for Digital Services, and for recipients of the service:

legal@keupera.com

1.2 Communications may be submitted in English or German. We will reply in the language in which you wrote.

1.3 Postal address, should one be required: Keupera, Ole Nepomuk Mai, Goethestrasse 70, 10625 Berlin, Germany. Electronic communication is faster and is preferred.

1.4 We have no legal representative under Art. 13 DSA, because we are established in the European Union.

1.5 This page is the notice and action mechanism required by Art. 16 DSA and describes the statements of reasons required by Art. 17 DSA.

2.1 Keupera is a hosting service within the meaning of Art. 3(g)(iii) DSA. Customers store content with us — articles, analyses, notes, comments, uploaded images, audit results — and can make some of it publicly accessible through share links and embedded widgets.

2.2 We are not an online platform within the meaning of Art. 3(i) DSA in the ordinary case, and we are not a very large online platform. The obligations in Section 3 of Chapter III DSA do not apply to us. The obligations in this document do, and we meet them regardless of our size.

2.3 We do not proactively monitor customer content, and we have no general obligation to do so under Art. 8 DSA. We act on notices, on our own detection of abuse, and on orders from competent authorities.

3.1 Anyone may notify us of content stored on our service that they consider illegal. Write to legal@keupera.com with the subject line "DSA notice".

3.3 Incomplete notices. If a notice does not contain enough for us to locate or assess the content, we will tell you what is missing rather than simply reject it.

3.4 Intellectual property. Copyright and trade mark complaints are handled through this same procedure. Please identify the right you hold and the basis on which you hold it.

3.5 Data protection requests. A request to erase personal data is not a DSA notice. Send those to legal@keupera.com under our Privacy Policy at /legal/privacy, and we will route them correctly.

4.1 Acknowledgement. We confirm receipt to the email address you provide, without undue delay.

4.2 Assessment. We assess every notice in a timely, diligent, non-arbitrary and objective manner. Where a notice enables a diligent provider to establish illegality without a detailed legal examination, we act expeditiously.

4.3 Human decision. Assessment is carried out by a human. We do not use automated means to decide whether content is illegal, and if that ever changes we will say so here, as Art. 16(6) DSA requires.

4.4 Possible outcomes. We may remove the content, disable access to it, restrict its visibility, suspend or terminate the account concerned, demote or delist it, or decide that no action is warranted.

4.5 Notification of the decision. We inform you of our decision, with reasons, and tell you what redress is available — including recourse to a court and to an out-of-court dispute settlement body certified under Art. 21 DSA.

4.6 Notification of the affected customer. Where we act against content, we give the customer concerned a statement of reasons under § 5.

4.7 Serious crime. Where we become aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of a person has taken place, is taking place or is likely to take place, we will inform the competent law enforcement or judicial authorities, as Art. 18 DSA requires.

5.2 Timing. The statement is provided at the latest at the moment the restriction takes effect. Where we must act immediately to protect a person or the security of the service, it follows without undue delay.

5.3 Exception. We do not provide a statement of reasons where the content is deceptive commercial content in high volume, or where an order from a judicial authority requires us not to inform the recipient.

5.4 Transparency database. We submit statements of reasons to the Commission's DSA Transparency Database where we are required to do so.

6.1 Who may complain. The customer affected by a decision, and the person who submitted a notice that we declined to act on.

6.2 How. Write to legal@keupera.com with the subject line "DSA complaint", within six months of being informed of the decision. Set out why you consider the decision wrong.

6.3 How we handle it. We handle complaints in a timely, non-discriminatory, diligent and non-arbitrary manner. The decision is reviewed by a human, and not by the same automated process that may have flagged the content. If we conclude the decision was wrong, we reverse it without undue delay and restore the content or the account.

6.4 Outcome. We inform you of the reasoned decision on your complaint and of the further redress available.

6.5 Out-of-court dispute settlement. You may bring the dispute before an out-of-court dispute settlement body certified under Art. 21 DSA by the Digital Services Coordinator of a Member State. We will engage in good faith with any such body. Its decision is not binding on either of us.

6.6 Courts. Nothing here affects your right to bring proceedings before a court.

6.7 Consumer arbitration. Separately from the DSA, and in accordance with § 36 VSBG, we are neither willing nor obliged to participate in dispute resolution proceedings before a German consumer arbitration board.

7.1 Manifestly illegal content. Where a customer frequently provides manifestly illegal content, we may suspend the provision of the Services to them for a reasonable period, after issuing a prior warning.

7.2 Manifestly unfounded notices and complaints. Where a person frequently submits notices or complaints that are manifestly unfounded, we may suspend the processing of their notices and complaints for a reasonable period, after issuing a prior warning.

7.3 How we assess misuse. We take account, in each case, of the absolute number of items concerned, their proportion of the total submitted, the gravity of the misuse and its consequences, and — where it can be identified — the intention behind it.

7.4 Warning first. We give a prior warning before any suspension under this section, and the warning explains what would need to change.

8.1 Orders to act against illegal content (Art. 9 DSA). On receipt of an order from a competent national judicial or administrative authority to act against one or more specific items of illegal content, we inform the issuing authority of the effect given to the order, specifying what we did and when.

8.2 Orders to provide information (Art. 10 DSA). On receipt of an order to provide specific information about one or more specific recipients, we inform the issuing authority of the effect given to it.

8.3 Notifying the affected recipient. We inform the recipient concerned of the order received and of the effect given to it, together with the redress available, at the latest at the time the effect is given, unless the order or applicable law provides otherwise — for example where informing them would prejudice an investigation.

8.4 Scope. We give effect only to orders that meet the conditions of Arts. 9 and 10 DSA, including the statement of reasons, the territorial scope limited to what is strictly necessary, and the identification of the issuing authority. We will say so where an order does not.

8.5 Records. We keep a record of orders received and of the effect given to them.

9.1 Where the rules are. The restrictions we place on customer content are set out in § 16 of our Terms of Service at /legal/terms and in our Acceptable Use Policy at /legal/acceptable-use. Both are written in plain language and are publicly accessible without an account.

9.2 How we enforce them (Art. 14 DSA). We apply those restrictions in a diligent, objective and proportionate manner, with due regard to the rights and legitimate interests of all parties involved, including the fundamental rights enshrined in the Charter of Fundamental Rights of the European Union — in particular freedom of expression and information, and the freedom to conduct a business.

9.3 Tools we use. We detect potential breaches through customer and third-party notices, through automated signals such as volume and rate anomalies, and through investigation of complaints. Automated signals may flag content for review; a human decides.

9.4 Escalation. Our enforcement escalates proportionately, as § 9 of the Acceptable Use Policy sets out.

9.5 Changes. We notify customers of significant changes to these restrictions before they take effect, in accordance with § 26 of the Terms of Service.

9.6 Not directed at minors. The Services are offered to businesses and professionals and require users to be at least 18. They are not designed for or directed at minors.