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This Moderation & Removal Policy describes how we handle notices of potentially illegal content and other rule breaches on https://tradersunion.com (the “Website”), operated by IAFT LTD (Cyprus).
The Policy reflects the approach of Regulation (EU) 2022/2065 (Digital Services Act, “DSA”) and applicable EU/Cyprus law (and, where relevant, UK standards), and explains:
• how to submit a notice;
• how we assess and decide (including timelines);
• what measures we may take (remove/restrict/annotate, etc.);
• how we provide a statement of reasons; and
• how re-review/appeals work (including internal complaint handling where applicable).
This Policy should be read together with our Terms of Use, Privacy Notice, User Reviews Policy, Trademark, Logo & Brand Use Complaints Policy and Complaints Handling Policy. For personal data matters, the Privacy Notice prevails.
Contact for notices under this Policy: compliance@tradersunion.com.
Contents:
4. Re-review/appeals, counter-notices, internal complaints and out-of-court settlement
5. Special content categories, policy interaction and transparency
Scope
This Policy applies to:
(a) user-generated content (UGC), including reviews and comments;
(b) editorial content and company profile materials to the extent a notice alleges potential illegality or third-party rights infringement; and
(c) submissions by users, companies, rightsholders and other persons alleging illegality or seeking restriction/removal.
What we mean by a “notice”
A “notice” is a submission made through the stated channel that contains sufficient information to identify the content and the grounds on which the notifier considers it illegal (or requiring restriction).
What we mean by “illegal content”
“Illegal content” means content that, based on substantiated information, may breach applicable law (e.g., unlawful personal data disclosure, threats, hate, fraud, counterfeit, IP infringement, etc.).
Important: lawful criticism, opinions and value judgments are not illegal content in themselves.
Moderation measures
“Moderation measures” may include removal, restriction of visibility, disabling access, annotation/clarification, demotion in ranking (where applicable), account-level restrictions, and other proportionate actions.
Submission channels
Notices of potentially illegal content and requests for moderation measures can be submitted:
• by email: compliance@tradersunion.com; and/or
• via a “Report” feature on the Website (where available), routed into our moderation workflow.
What your notice should include (minimum)
To enable timely identification and assessment, a notice should include:
(a) Notifier identification and contact
• name / organisation;
• capacity: user / company / rightsholder / authorised representative / other;
• contact email;
• where acting as a representative, evidence of authority where feasible.
(b) Precise content identification
• specific URL(s) on the Website;
• where helpful, screenshots and/or page-location details (title, date, username, excerpt).
(c) Grounds and qualification
• what is allegedly illegal or otherwise in breach;
• relevant category (e.g., unlawful personal data disclosure, threats/harassment, hate speech, fraud, IP infringement, misleading advertising, etc.);
• the specific disputed parts (ideally quoted or clearly pointed out).
(d) Requested action
• remove / restrict visibility / edit (e.g., redact personal data) / add annotation / other specific measure.
(e) Good-faith statement
A good-faith confirmation that, to the notifier’s knowledge, the information provided is accurate and that the notice is not submitted to pressure or censor lawful content.
What we consider “sufficient information”
A notice is sufficient to start review where:
• the content can be clearly located (URL/identifiers); and
• the notice provides specific grounds explaining why it may be illegal or in breach; and
• we have a contact for response.
Where this threshold is not met, we may request clarifications (see 2.4).
Incomplete notices and requests for clarification
If a notice is incomplete, we may:
• request missing information (e.g., correct URL/screenshot/quoted section);
• pause review until the necessary details are provided;
• in urgent cases (e.g., apparent personal data disclosure), take a temporary proportionate measure pending assessment where justified by risk (e.g., restrict visibility/redact a fragment).
Abusive notices
We aim to protect the notice-and-action process from abuse (e.g., mass repetitive demands without grounds, attempts to suppress lawful criticism, spam notices).
Where abuse indicators exist, we may:
• request additional substantiation;
• consolidate repetitive notices on the same matter;
• apply reasonable rate-limiting to repetitive manifestly unfounded notices;
• reject manifestly unfounded notices with recorded reasons.
We do not use this mechanism to avoid handling well-founded notices and we maintain a fair balance with freedom of expression.
Requests from authorities / regulators
Requests from competent authorities (including courts/regulators) relating to content restriction/removal or data requests should be sent to compliance@tradersunion.com.
We may request:
• verification of authority/jurisdiction;
• the legal basis and scope;
• document/order details as applicable.
Such requests are handled in line with applicable law and our Privacy Notice, including data minimisation.
Trusted flaggers (where applicable)
Where a notice is submitted by an entity acting as a DSA “trusted flagger” (where applicable to our service), please include:
• proof/identifier of the status;
• authorised contact details;
• URLs/materials enabling rapid identification and assessment.
We prioritise such notices to the extent feasible, while maintaining fairness and proportionality.
Acknowledgement
After receiving a notice, we typically:
• acknowledge receipt (including via automated confirmation), usually within 48 business hours; and
• request clarifications where needed (see Article 2)
Initial assessment and prioritisation
We perform an initial assessment, including:
• whether the notice contains sufficient information (URL/grounds/contact);
• risk category (e.g., personal data, threats/violence, fraud, counterfeit/IP, etc.);
• whether urgent interim measures may be needed.
Urgent cases. Where a notice indicates an obvious and significant risk (e.g., personal data disclosure, threats, clear fraud), we may apply a temporary proportionate measure (e.g., restrict visibility/redact a fragment) pending full assessment.
Substantive review
We assess content in context (the whole page, surrounding elements, ad/affiliate labels, disclaimers, quotation/context, publication date) and consider:
• applicable law and our rules (Terms of Use and related policies);
• balancing of rights and interests (including freedom of expression and public interest);
• evidence provided by the notifier and, where applicable, the content author/company.
Timelines
We aim to handle notices within reasonable timeframes:
• standard — typically within 10 business days once we have sufficient information;
• complex matters (e.g., additional verification, contextual/legal assessment) — typically within 30 calendar days, with an update and reasons;
• where essential information is missing, timelines may be paused until clarifications are received.
These timeframes are targets (“we aim”) and may vary depending on complexity, volume and notice type.
Possible measures (outcomes)
Following review, we may take one or more of the following measures:
(a) leave content unchanged (where no breach is found);
(b) restrict visibility (temporarily or permanently) or hide content;
(c) remove content (in whole or in part);
(d) edit/redact (e.g., remove personal data or harmful technical elements) while preserving lawful meaning where feasible;
(e) add an annotation/clarification (e.g., context note, “unverified”, link to rules, warning);
(f) demote content in display/ranking (where the feature exists);
(g) account-level measures (e.g., temporary posting restrictions/suspension for repeat breaches), in line with the Terms of Use and related policies.
We aim to apply the least intrusive measure sufficient to address the breach/risk, consistent with proportionality.
Decision notice and statement of reasons
Where we decide to remove/restrict/otherwise intervene in content availability due to potential illegality or rule breaches, we typically:
• document the decision and key grounds; and
• notify the relevant party (content author and/or notifier, depending on the scenario and available contact).
A “statement of reasons” typically includes (to the extent reasonable):
• what measure was taken;
• the main reasons (category of breach/risk);
• the relevant policy/standards at a high level (without exposing details that enable abuse); and
• information on re-review/appeal options (see Article 4)
Special cases: personal data and safety
Where a notice concerns unlawful personal data disclosure or other high-risk scenarios, we may:
• promptly restrict access to the relevant fragment;
• request additional substantiation where needed; and
• implement additional protective measures (e.g., enhanced masking/filters) without disclosing anti-abuse specifics.
Right to request a re-review (appeal)
If you disagree with our decision on a notice (e.g., we removed/restricted content or refused removal), you may request a re-review by emailing compliance@tradersunion.com within 30 calendar days of our notice (or when you reasonably became aware of the decision).
Suggested subject line:
“DSA Appeal / Re-review — [short description]”.
Please include:
• the relevant URL(s) and/or identifiers;
• which decision you challenge;
• reasons for disagreement and any new facts/documents.
Counter-notice by the content author
Where our measure affects a user/content author (e.g., a review/comment is hidden/removed), the author may submit a counter-notice to compliance@tradersunion.com.
A counter-notice should include:
• content identification (URL, date/time, username/ID where known);
• why the author believes the content is lawful and compliant;
• where relevant, reasonable supporting context/evidence (redacted as needed), without excessive personal data.
We may notify the original notifier that a counter-notice was received where appropriate and subject to confidentiality, and we may reassess our decision.
Re-review timelines
We aim to handle re-review requests within reasonable timeframes:
• typically within 10 business days after receiving sufficient information; and
• up to 30 calendar days for complex matters, with an update and reasons.
Internal complaint handling (DSA approach)
Where a moderation action falls under DSA processes (e.g., restriction/removal due to alleged illegality), you may submit an internal complaint via compliance@tradersunion.com.
We review internal complaints:
• objectively and without discrimination;
• considering context, balancing of rights and applicable rules; and
• we provide a response with a brief statement of reasons.
An internal complaint does not limit your right to use other remedies, including out-of-court settlement and courts (see 4.5–4.6).
Out-of-court dispute settlement
Where applicable, parties may use out-of-court dispute settlement mechanisms available under applicable law/practice (e.g., DSA-certified dispute settlement bodies where available).
We may participate in good faith where:
• the dispute relates to a moderation/restriction decision; and
• the mechanism is recognised/appropriate in the relevant jurisdiction.
Court remedies and other legal routes
Nothing in this Policy limits any party’s right to contact:
• competent authorities/regulators; and/or
• courts.
Abuse prevention and repeat infringers
We aim to prevent abuse of the notice-and-action and moderation processes, including:
• systematically manifestly unfounded notices;
• mass attempts to suppress lawful criticism; and
• repeat breaches by users (repeat infringers).
Depending on the circumstances, we may:
• request further substantiation;
• rate-limit repetitive manifestly unfounded notices; and/or
• apply proportionate account-level measures for repeat breaches (e.g., temporary posting restrictions), in line with the Terms of Use.
Intellectual property (trademarks/logos/copyright)
(a) Trademarks, logos and brand identifiers
Rightsholder requests regarding trademarks/logos/company names (e.g., “remove our logo/name”, “misleading affiliation impression”) are handled with reference to our Trademark, Logo & Brand Use Complaints Policy.
Where a submission is a DSA notice alleging illegality, we apply the DSA process and, where relevant, the specialised trademark/logo criteria.
(b) Copyright
Copyright notices typically require:
• precise identification of the protected material and where it appears;
• proof of ownership, licence, or authority to act on behalf of the rightsholder; and
• an explanation of why the use is unlawful and not covered by applicable exceptions/quotation (where relevant).
We may restrict/remove content where sufficient grounds exist.
Personal data and privacy (GDPR/UK GDPR)
Where a notice concerns unlawful disclosure of personal data (e.g., addresses, phone numbers, emails, payment details, IDs) or other privacy issues, we may:
• take urgent interim measures (e.g., restrict visibility/redact) pending assessment;
• request only the minimum information needed; and
• process notifier/author personal data in line with our Privacy Notice and data minimisation principles.
Defamation, false allegations and “disagreement with criticism”
We distinguish between:
• opinions/value judgments (generally permissible); and
• verifiable factual claims that may be unlawful (e.g., defamation, unsubstantiated criminal allegations, demonstrably false claims causing harm).
We do not remove content merely because it is negative or uncomfortable for a company.
Where illegality is alleged, the notifier should specify:
• the exact disputed parts;
• why they are unlawful/false; and
• supporting materials where feasible, without disclosing excessive personal data.
Fraud, malicious content and user safety
Where content involves:
• fraud/phishing,
• malicious links/software,
• incitement to unlawful conduct, or
• threats/violence,
we may:
• promptly restrict or remove content;
• apply account-level restrictions; and/or
• retain minimal technical logs for abuse/security purposes (in line with our Privacy Notice).
Advertising, financial communications and misleading presentation
Where a notice relates to:
• ad/sponsored/affiliate labelling,
• potentially misleading claims near CTAs, or
• mixing editorial and advertising content, we assess the context in line with our Advertiser & Affiliate Disclosure, Editorial Guidelines, and the principle of fair, clear and not misleading communications.
Possible measures include strengthening labels, adjusting wording, adding annotations, moving/separating blocks, or restricting display.
Interaction with other policies (procedural hierarchy)
This Policy should be read together with:
In case of inconsistency:
• Privacy Notice prevails for personal data;
• the trademark/logo policy applies as the specialised policy for trademark/logo matters;
• UGC standards (where not about illegality) are governed by the reviews/fake reviews policies; and
• notice-and-action/statement of reasons/appeals are governed by this Moderation & Removal Policy.
Record-keeping and transparency
We maintain internal records of notices and decisions to the extent necessary to:
• meet legal requirements,
• ensure consistency of decisions, and
• prevent abuse and repeat infringements.
Where appropriate, we may publish aggregated transparency information (e.g., a transparency summary) without personal data or confidential details, to increase procedural transparency (DSA approach).
Single point of contact
For notices, moderation matters, restriction/removal requests, appeals and re-review submissions under this Policy, please contact: compliance@tradersunion.com.
Where the Website offers additional tools (e.g., a “Report” button), those are supplementary channels routing submissions into our workflow; however, legally significant materials and case correspondence may be handled via email.
Language
We accept notices and related submissions in English or Russian.
Where necessary and reasonable, we may request clarification/translation of key elements to ensure proper assessment (e.g., to understand the alleged legal grounds accurately).
Retention of case materials (brief)
We may retain information about notices, decisions and correspondence (including minimal technical logs where applicable) to the extent and for the period necessary to:
• meet legal requirements and demonstrate procedural compliance;
• prevent abuse and repeat breaches; and
• protect the rights and legitimate interests of users, notifiers and the Company.
For details on personal data, retention and data subject rights, see our Privacy Notice.
Territorial scope (EU/Cyprus/UK)
The Website is operated by IAFT LTD (Cyprus) and serves an international audience. We apply an approach compatible with EU requirements (including the DSA where applicable to our role/service) and, where relevant, we take into account consumer protection and digital regulatory standards applicable to users in other jurisdictions (including the UK), to the extent required and appropriate.
Effective date
This Policy is effective upon publication on the Website and applies to notices and moderation actions taken after that date. It replaces prior versions of moderation/notice-and-action procedures unless expressly stated otherwise.
Updates
We may update this Policy from time to time (e.g., due to Website changes, moderation practice updates, or legal/regulatory developments). The current version is published on the Website and the “Last updated” date appears at the top.
Where changes are material, we may provide notice to users by reasonable means (e.g., a Website notice).
