EU Digital Services Act — Notice & Action

Effective date: 1 August 2026 · Version 2.0

This document explains how APERTURESyndicate OÜ complies with the EU Digital Services Act (Regulation (EU) 2022/2065, the "DSA") as a provider of hosting services. It tells you how to report illegal content, what happens next, what we tell you if we act on something of yours, and — just as importantly — which DSA mechanisms we are exempt from and therefore do not operate.

Who we are. APERTURESyndicate OÜ is a micro enterprise established in Republic of Estonia (EU): two people, no external staff. We are not a Very Large Online Platform or Very Large Online Search Engine, and we are not subject to the obligations that apply only to those services.

What we host. Content created by our users across the Services listed in Section 2 of the Terms of Service — messages and uploads in Chat, AI conversations and characters in ASAI, music and artwork, datasets, profiles, and developer-facing content. The platform is for people aged 16 and over.

Our role. We are an intermediary host. We do not author user content and we do not generally monitor it. We provide a clear way to report illegal content, we act on valid reports and on orders from competent authorities, and we give affected users reasons for what we did.

We write these documents in good faith and keep them accurate to how the platform actually works. They have not yet been reviewed by qualified Estonian legal counsel.

1. Scope

This document is our general illegal-content mechanism. It sits alongside:

Copyright & Takedown — copyright and trademark notices follow that procedure and reach the same inbox.
Acceptable Use Policy — what our own rules forbid, independently of whether content is illegal.
Terms of Service, Section 10 — the description of how our content moderation actually works, required by Article 14 of the DSA.

2. Points of contact

We operate a single electronic point of contact that serves both roles the DSA requires:

Address: [email protected]
For Member State authorities, the European Commission and the European Board for Digital Services (Article 11) — to communicate with us directly on the application of the DSA.
For users and members of the public (Article 12) — to communicate with us directly and rapidly, by electronic means.
Languages: English or Estonian. The English version of this document is the controlling one.

We do not designate an EU legal representative under Article 13 because we are established inside the Union, in Republic of Estonia (EU).

3. Reporting illegal content (Article 16)

Anyone may notify us of content they consider illegal — you do not need an account. Send your notice to [email protected] with "Illegal content" in the subject line.

Please include all of the following, so that we can act without a detailed legal investigation:

Where the content is — a direct link wherever possible. If there is no link, describe it precisely enough that we can find it without an unreasonable manual search: the Service, the profile, the conversation, the track, the dataset, the image, and where it appears.
Why you believe it is illegal — which law you think it breaks and why. The more concrete this is, the faster we can assess it.
Your name and email — so we can acknowledge the notice and tell you the outcome. This is not required for notices about suspected child sexual abuse material or comparable offences, where anonymous reporting is appropriate.
A statement of good faith — that you believe the information in your notice is accurate and complete.

A notice containing enough information for a diligent provider to identify the illegality without a detailed legal examination gives us actual knowledge of that content under EU intermediary-liability law.

Timing. We aim to confirm receipt within 72 hours and to tell you the outcome once we have assessed it. We are two people; if a notice is complex or arrives during a holiday, it may take longer. We would rather say that here than publish a deadline we cannot always meet.

4. What we do with a notice

We assess every notice in a timely, diligent, non-arbitrary and objective way. Decisions that affect a specific piece of content or an account are made by a person, not by an automated system.

Where we conclude that content is illegal, or that it breaches the Acceptable Use Policy or our other terms, we choose the least intrusive measure that fits the case. That may be to:

remove the content or disable access to it;
restrict its visibility — for example unlist it or age-gate it;
restrict, suspend or terminate the account responsible, or its ability to publish or upload;
end monetisation or other commercial features connected to the content; or
report the matter to the competent authorities where the law requires it.

Where content is lawful but breaks our own rules, we act under our terms rather than under legal compulsion. The same safeguards in this document apply either way.

If we take no action, we say so and explain why. A notice we decline is still logged.

5. Statement of reasons (Article 17)

Whenever we restrict content or act against an account because the content is illegal or incompatible with our terms, we give the affected user a clear and specific statement of reasons, unless the law prevents us — for example where an authority order forbids disclosure.

The statement tells you, as applicable:

what we did — removal, disabling, visibility restriction, feature restriction, suspension or termination — and its territorial and temporal scope;
the facts and circumstances we relied on, including whether we acted on a notice from a third party, on an order from an authority, or on our own detection;
whether automated means were used in detecting the matter or in making the decision;
the legal ground (which law) or the contractual ground (which rule of ours) we relied on; and
what you can do about it — Section 6.

We keep a record of the statements of reasons we issue.

6. If you disagree with a decision

Write to us and we will look again. Reply to the notice, or write to [email protected] with "Appeal" in the subject line, and tell us what you think we got wrong. A person re-reads the decision and the content, and we tell you the outcome. If we were wrong, we reverse it.

We do not attach a deadline to this, because we are not running a formal complaint system and we do not want to pretend otherwise — see Section 7.

Going to court. Nothing here affects your right to bring proceedings before the courts of Tallinn in accordance with applicable law, or, if you are a consumer, before the courts of the country where you live. Any other remedy available to you under EU or Estonia law is also unaffected.

Regulatory routes. If you believe we are not meeting our obligations under the DSA, you may complain to the Digital Services Coordinator of the Member State where you live or where we are established. For data-protection matters the route is Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate) — https://www.aki.ee/en · [email protected]. For consumer matters in Republic of Estonia (EU), the Tarbijakaitse ja Tehnilise Järelevalve Amet (TTJA) — https://www.ttja.ee · [email protected].

7. What we do not operate, and why

We would rather tell you plainly what does not exist than describe a procedure you would then try to use.

Article 19 of the DSA exempts providers that qualify as micro or small enterprises from Section 3 of Chapter III. We are a micro enterprise, and we rely on that exemption. Accordingly we do not operate:

an internal complaint-handling system under Article 20 — there is no formal appeal, no six-month appeal window and no decision deadline. What we do instead is in Section 6: you write to us, a person re-reads the decision.
out-of-court dispute settlement under Article 21 — we have not committed to any certified dispute-settlement body. Your right to go to court is unaffected.
trusted-flagger priority under Article 22 — we have no priority queue. Notices from recognised organisations are welcome and, in practice, usually easier to act on because they are well substantiated, but they receive no formal precedence.
the misuse-suspension procedure under Article 23. We may still decline to process notices from someone who repeatedly sends manifestly unfounded or bad-faith reports, and we may act against an account that repeatedly posts manifestly illegal content — but as a matter of our own terms, proportionately and case by case, not under an Article 23 procedure.

Article 15(2) exempts us from publishing periodic transparency reports, and we do not publish one. An earlier version of this document promised an annual moderation summary; we withdrew that promise rather than publish something half-kept.

If we grow past the micro-enterprise threshold, these exemptions stop applying. We will then build what the law requires and update this document before doing so.

8. Orders from authorities

Orders to act against illegal content (Article 9). Where we receive an order from a competent national judicial or administrative authority to act against specific illegal content, we act on it and inform the issuing authority of the effect given to it. We confirm receipt without undue delay and — unless the order or the law says otherwise — we inform the affected user of the order and of the action taken, including its territorial and temporal scope.

Orders to provide information (Article 10). Where we receive a valid order to provide specific information about one or more users, we respond in accordance with the order and the law, and we inform the affected user where we are permitted to do so.

We act on such orders only to the extent specified and required, and only where the order contains the elements the DSA requires — a statement of reasons, the precise location of the content, and information about redress.

9. Serious threats to life or safety (Article 18)

If 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 inform the competent law-enforcement or judicial authorities and give them the information we have.

For child sexual abuse material we act immediately and without warning: we remove and preserve the material as the law requires, terminate the account, and report to the competent authorities. See Acceptable Use Policy, Section 2.

If a person is in immediate danger, contact your local emergency services first. We are not an emergency service and we cannot respond at that speed.

Contact

Purpose	Contact
Illegal-content notices, authority communications	[email protected] — subject "Illegal content"
Disagreeing with a moderation decision	[email protected] — subject "Appeal"
Copyright and trademark	[email protected] — see Copyright & Takedown

We accept correspondence in English or Estonian.

APERTURESyndicate OÜ Registry code 17384111 · VAT EE102972654 Priisle tee 8, Lasnamäe linnaosa, Tallinn, Harju maakond, 13914, Estonia Company registration details

This document is governed by the law of Estonia, with the courts of Tallinn having jurisdiction, and is subject to the EU Digital Services Act (Regulation (EU) 2022/2065) and applicable Estonia and EU law. The English-language version is the controlling version.

Version history

v2.0 — 2026-08-01 — Rewritten to match what we actually operate. Removed the promised internal complaint-handling system, out-of-court dispute settlement, trusted-flagger priority, the Article 23 misuse procedure and the annual transparency summary — all of them mechanisms the Article 19 micro-enterprise exemption relieves us of and none of which we run. Added an explicit statement of which exemptions we rely on, replaced the formal appeal with the honest "write to us and a person re-reads it", and converted the company and contact details to shared placeholders.
v1.0 — 2026-06-22 — Initial publication.