Trademark, Logo & Brand Use Complaints Policy

Contents:

1. General provisions

2. Objectives of the policy

3. Trademarks and logos — key provisions

4. How to submit a complaint (notice) and required information

5. Review process and possible outcomes

6. Appeals, counter-notices and re-review

7. Limitation of liability and important clarifications

8. Contact and complaints route

9. Final provisions

• 1.1

  About this Policy

  IAFT LTD (hereinafter “we”, “our”, “us”, “Traders Union” or the “Company”), a company registered at 6 Vasili Vryonides Street, Gala Court Chambers, 5th Floor, Offices 501–502, Office O, 3095 Limassol, Cyprus, is the operator of https://tradersunion.com (the “Website”).

  This Trademark, Logo & Brand Use Complaints Policy (the “Policy”) sets out the objectives, principles, grounds and procedures for handling requests from rightsholders and other complainants seeking to remove, replace, restrict, edit, annotate or correct content on the Website due to alleged improper use of trademarks, logos, company names and other brand identifiers.

  The Policy applies to content published on the Website, including (without limitation): company/broker profiles, ratings and evaluation methodologies, comparison tables, reviews, user-generated content (reviews/comments), and other analytical or reference materials, including situations where a complainant alleges that the use may create a misleading impression of affiliation, endorsement or partnership.

  This Policy is specialised for trademark/logo/name-related complaints. For notices concerning illegal content and other categories of complaints not related to trademarks, our separate Moderation & Removal Policy (DSA / Notice & Action) applies.

• 1.2

  Legal framework

  This Policy has been developed with regard to applicable requirements and best practices, including:

  (a) European Union legislation, including:

  • • Regulation (EU) 2022/2065 (Digital Services Act, “DSA”);

  • • Regulation (EU) 2017/1001 on European Union trade marks (“EUTMR”);

  • • Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”);

  • • Directive 2000/31/EC (e-Commerce Directive);

  • • Charter of Fundamental Rights of the European Union (Article 11).

  (b) The legislation of the Republic of Cyprus.

This Policy aims to achieve the following objectives:

• a

  Transparent and predictable process for rightsholders.

  To provide a clear procedure for submitting and handling trademark/logo/company name complaints, including information/evidence requirements, timelines and possible outcomes.

• b

  Balancing IP rights with public interest and freedom of expression.

  To respect rightsholders’ lawful trademark rights and reputation while maintaining editorial independence and the public interest in access to comparative and reference information (including reviews, ratings and profiles).

• c

  Preventing user confusion.

  To address cases where the use of names/logos/brand identifiers may create a misleading impression of affiliation, endorsement, partnership or official status, or otherwise mislead users.

• d

  Correcting factual inaccuracies and keeping identification details up to date.

  To correct substantiated factual errors (e.g., incorrect company name, outdated logo, incorrect identifiers), where appropriate and feasible, with minimal interference in editorial assessment.

• e

  Preventing abuse (“abusive notices” / trademark bullying).

  To reduce the risk of complaints being used as a pressure tactic to censor or remove content without proper legal grounds, and to identify manifestly unfounded or repetitive abusive requests.

• f

  Compliance with applicable law and best practices.

  To ensure compliance with applicable EU/Cyprus (and, where relevant, UK) requirements, including the DSA approach to handling notices, and consumer protection principles of fair, clear and not misleading communications.

• g

  Efficient and timely handling.

  To ensure reasonable review timelines, documented decisions and clear communication of outcomes to complainants, including applicable appeal/review options.

• 3.1

  Lawful referential (identification) use

  We may use company names, trademarks and/or logos on the Website solely for identification purposes (for example, to clearly identify a company/service in a profile, review, rating or comparison table).

  Under EU law, such use may be permitted within trademark limitations, including referential use, provided it is consistent with honest commercial practices and does not mislead users.

• 3.2

  Legal standards (what we assess)

  When handling a complaint, we assess the use of the mark/logo in its full context. As a rule, use is considered appropriate where the following criteria are met:

  (a) the primary purpose is identification of the company/product/service being discussed;

  (b) the use is consistent with honest commercial practices;

  (c) it does not suggest that the rightsholder owns the Website or that there is endorsement, partnership or affiliation;

  (d) the size/placement/context is proportionate to the informational purpose (it does not dominate the page as if it were an “official brand” of the page);

  (e) it does not create a likelihood of confusion for an average user;

  (f) where relevant, we ensure additional transparency (e.g., clear ad/affiliate labelling and non-affiliation context).

• 3.3

  Response to “no consent / no permission” complaints

  3.3.1. Handling rightsholder objections

  A request to remove a mark solely because there is no written permission is typically not sufficient where the use is referential/identificatory and not misleading. However, where a complainant identifies specific issues (e.g., misleading impression of endorsement/affiliation; use in an advertising context without appropriate labelling; outdated/incorrect logo; other legal concerns), we will assess and, where appropriate, take corrective action (see Article 4 below and subsequent Articles).

  We encourage complainants to provide supporting documentation (e.g., official brand guidelines, registration references, and a clear explanation of which page element is problematic and what change is requested).

  3.3.2. Advertising, commercial relationships and non-affiliation

  The Website may contain advertising materials, sponsored placements and/or affiliate links to third parties.

  We aim to ensure that:

  • • advertising/sponsored elements are clearly labelled (e.g., “Advertisement”, “Sponsored”, “Paid placement”, “Affiliate link”); and

  • • users are not misled into believing that the presence of a logo/name implies official partnership, endorsement or affiliation, unless that is the case.

For details on our commercial relationships and transparency approach, see our Advertiser & Affiliate Disclosure.

• 4.1

  Submission channels

  Trademark/logo/company name complaints and related requests should be submitted to: compliance@tradersunion.com (and/or via the Website form, where available).

  To help us route your request quickly, please use the subject line: “Trademark/Logo Complaint — [Company/Brand Name]”.

• 4.2

  What your notice should include (minimum information)

  To enable a timely and accurate review, please include:

  (a) Complainant identification and authority

  • • your full name / organisation name;

  • • your capacity: rightsholder / authorised representative (agent/lawyer) / other;

  • • contact details (email and, where relevant, phone);

  • • if acting as a representative, evidence of authority (e.g., authorisation letter/power of attorney or verifiable official contact reference).

  (b) Precise content identification

  • • specific URLs of the relevant page(s) on the Website;

  • • screenshots of the relevant element (recommended);

  • • what exactly is complained about: logo, word mark/company name, domain reference, visual element, etc.

  (c) Grounds for the complaint

  • • a clear explanation of why the use is allegedly unlawful or misleading;

  • • what specific risk you identify (e.g., impression of affiliation/endorsement; use in an advertising context without proper labelling; outdated/incorrect logo; other);

  • • where available, references to relevant materials (e.g., official brand guidelines, legal references) (optional but helpful).

  (d) Evidence of rights (for rightsholders)

  • • trademark registration details (number/jurisdiction/classes) and/or other evidence of rights;

  • • link to the official website or official sources confirming the brand/logo.

  (e) Requested action (what you want us to do)

  Please specify the requested outcome, such as:

  • • remove/replace a logo;

  • • correct a company name;

  • • add a non-affiliation clarification;

  • • adjust placement/size to avoid misleading impressions;

  • • other specific change.

• 4.3

  Types of requests we assess

  We assess, in particular, requests alleging:

  • • misleading impressions of affiliation/endorsement/official partnership;

  • • use in a context that may be perceived as advertising/promotion without proper labelling;

  • • use of outdated/incorrect brand identifiers (e.g., old logo);

  • • other cases where use goes beyond identification purposes or violates applicable requirements.

• 4.4

  Incomplete or abusive notices

  If a notice lacks sufficient information, we may request clarifications. Review may be paused until we receive the necessary details.

  We may also reject manifestly unfounded or abusive notices (e.g., repetitive requests without new information, attempts to suppress factual content without legal grounds), and we will provide a brief explanation.

• 5.1

  Acknowledgement and initial checks

  After we receive a notice, we typically:

  • • acknowledge receipt (or send an automated acknowledgement); and

  • • perform an initial completeness review (see Article 4).

  If the information is insufficient, we may request clarifications. Review may be paused until the necessary details are provided.

• 5.2

  Assessment (how we decide)

  We assess each complaint in its full context, including (without limitation):

  • • the nature of the use (referential/identification vs promotional/advertising);

  • • page context and visual presentation (size, placement, proximity to CTAs, advertising blocks, labels);

  • • risk of misleading users (affiliation/endorsement/official status);

  • • whether appropriate disclosures/labels are present (e.g., “Advertisement”, “Sponsored”, “Paid placement”, “Affiliate link”);

  • • accuracy and currency of brand identifiers (e.g., outdated logo/name);

  • • the evidence of rights and arguments provided.

  Where appropriate, we aim to apply the least intrusive measure sufficient to address the issue (e.g., adding clarity or replacing an outdated logo rather than removing all references), depending on the circumstances.

• 5.3

  Review timelines

  We aim to handle complaints within reasonable timelines:

  • • Acknowledgement: typically within 2 business days.

  • • Standard review: typically within 10 business days.

  • • Complex cases (e.g., contextual/legal disputes or where additional verification is needed): up to 30 calendar days, with an update and reasons.

  Timelines may vary depending on the complexity of the request and how quickly additional information is provided.

• 5.4

  Possible actions (outcomes)

  Following review, we may take one or more of the following actions:

  (a) Remove the relevant element (e.g., a logo) or a part of a page;

  (b) Replace/correct (e.g., update an outdated logo, correct a company name, fix identifiers);

  (c) Adjust context/placement (e.g., change size/position to avoid dominance or an “official” appearance);

  (d) Add an annotation/clarification (e.g., non-affiliation clarification, “updated” notice, source clarification);

  (e) Strengthen ad/sponsorship labelling near the relevant block/CTA where the issue relates to promotional context;

  (f) Reject the complaint where we find no breach or risk requiring corrective action.

• 5.5

  Decision notice (“statement of reasons”)

  We inform the complainant of the outcome and typically include:

  • • the decision taken (actions or rejection);

  • • the key reasons (to the extent appropriate and permitted); and

  • • where relevant, what additional information would be required to reassess.

  If the action affects a user/content author (e.g., a review/comment), we may notify the author (to the extent we have contact details and where required), including a brief statement of reasons and information about appeal/review options (see Article 6).

• 6.1

  Right to appeal (re-review)

  If you disagree with our decision, you may request a re-review (appeal) by emailing compliance@tradersunion.com within 30 calendar days of our response (unless we specify a different timeframe in the decision notice).

  Please include:

  • • subject line: “Trademark/Logo Appeal — [Company/Brand Name]”;

  • • the relevant URL(s) and a brief description of the disputed element;

  • • the reasons for disagreement and any new facts/documents not previously provided.

• 6.2

  Counter-notice and content author position

  Where a complaint concerns user-generated content or other third-party submitted content on the Website and our action affects the content author (e.g., removal/hiding of a review/comment), the author may submit a counter-notice to compliance@tradersunion.com.

  A counter-notice should include:

  • • content identification (URL, publication date/time if known);

  • • an explanation of why the author believes the content is lawful (including the context of the trademark/logo use);

  • • any supporting evidence.

  We may notify the original complainant that a counter-notice has been received (where appropriate and subject to confidentiality requirements) and re-assess our decision. In certain cases, we may restore the content or apply an alternative measure (e.g., an annotation/clarification), where lawful and appropriate.

• 6.3

  Appeal review timelines

  We aim to handle appeals within reasonable timelines:

  • • typically within 10 business days; and

  • • up to 30 calendar days for complex matters (with an update and reasons).

• 6.4

  Abusive notices and repeat complaints

  We reserve the right to:

  • • reject manifestly unfounded or repetitive notices that present no new information; and/or

  • • limit processing where we identify abuse of the procedure (e.g., mass takedown demands without proper grounds, attempts to suppress factual content).

  Where feasible, we will provide a brief explanation.

• 6.5

  Other dispute resolution routes and legal remedies

  This Policy does not limit any lawful rights to contact competent authorities or courts. However, we encourage complainants to use this Policy process first where possible, as it often enables prompt, practical fixes (e.g., updating an outdated logo, clarifying labelling, or adding a non-affiliation clarification).

• 7.1

  Informational nature and non-affiliation

  The Website is provided for informational/educational purposes. We are not a trading platform or broker, we do not execute trades, act as an agent for brokers, or provide investment advice or personal recommendations.

  The presence of company names, trademarks and/or logos on the Website is generally for identification purposes and does not, by itself, imply partnership, endorsement, affiliation or official status unless expressly stated.

• 7.2

  Third-party control limitations

  We do not control the content, policies or technologies (including trademark/logo use) on third-party websites linked from the Website. Once you follow a link, your relationship is governed by the relevant third party’s terms and policies.

• 7.3

  No guarantee of a specific outcome

  We will review complaints in good faith in accordance with this Policy; however, we cannot guarantee that every request will be granted. Decisions depend on the circumstances, applicable law, the evidence provided, and our assessment of potential user confusion.

• 7.4

  Confidentiality and personal data

  When handling notices, we may process complainant/representative contact details and other information. Such processing is carried out in accordance with our Privacy Notice. We may limit the disclosure of details to third parties where necessary to protect confidentiality, rights and prevent abuse.

• 7.5

  Changes to this Policy

  We may update this Policy from time to time (e.g., to reflect changes in law/practice, internal processes, or the Website functionality). The current version is available on the Website and the “Last updated” date appears at the top of the document.

• 8.1

  Contact for rightsholder complaints (Trademark/Logo/Name)

  All trademark/logo/company name complaints relating to the Website should be sent to: compliance@tradersunion.com.

  Suggested email subject lines:

  • • “Trademark/Logo Complaint — [Company/Brand Name]” (initial notice), or

  • • “Trademark/Logo Appeal — [Company/Brand Name]” (appeal).

• 8.2

  Format

  To help us review promptly, please:

  • • provide specific URLs and screenshots; and

  • • clearly identify the disputed element and the requested action (see Article 4).

• 8.3

  Related policies

  This Policy applies to trademark/logo/name-related complaints. We also recommend reviewing:

  • • our Advertiser & Affiliate Disclosure (commercial relationships and ad/affiliate labelling);

  • • our Privacy Notice (personal data processing); and

  • • our Complaints Handling Policy (general complaints process) — where published on the Website.

• 8.4

  Updates

  The current version of this Policy is available on the Website and the “Last updated” date appears at the top of the document.

• 9.1

  Document hierarchy and consistency

  This Policy governs how we handle complaints and requests relating to the use of trademarks, logos and company names on the Website.

  To the extent we process personal data when handling notices, our Privacy Notice applies.

  Use of the Website more generally is governed by our Terms of Use. In case of any inconsistency, the Terms of Use and the Privacy Notice prevail within their respective scope.

• 9.2

  Severability

  If any provision of this Policy is held invalid or unenforceable, the remaining provisions remain in full force and effect to the maximum extent permitted.

• 9.3

  No waiver

  Our failure or delay in enforcing any provision of this Policy does not constitute a waiver of our rights and does not prevent us from enforcing it later.

• 9.4

  Governing law and dispute resolution

  This Policy should be interpreted in accordance with applicable law. Depending on the nature of the dispute and applicable rules, parties may seek to resolve issues via the process described in this Policy and/or through other lawful routes (including competent authorities/courts).

• 9.5

  Contact

  For matters relating to this Policy: compliance@tradersunion.com.