DSA & OSA
Notice-and-Action

1. Scope

This policy applies to VLStudio Web at vlstudio.live, operated by Vladyslav Zhminko, trading as VLStudio ("VLStudio", "we", "us", "our"), Carrer de Valencia 191, 6.1, 08011, Barcelona, Spain, an intermediary service and online platform within the meaning of the EU Digital Services Act (Regulation (EU) 2022/2065), and, separately, a regulated service within the meaning of the UK Online Safety Act 2023. It covers all content VLStudio hosts on behalf of users: community posts and comments, marketplace listings, and job postings, not community posts alone.

2. Notice-and-Action Mechanism (Article 16)

Anyone can notify VLStudio of specific content they consider to be illegal, at any location on the Service, using the contact details in Section 12. A notice under this policy should include: a sufficiently precise and adequately substantiated explanation of why the content is considered illegal; the exact electronic location of the content (a direct URL); the name and email address of the person submitting the notice, except where the content concerns one of the categories of alleged offense for which anonymous reporting is required; and a statement of good faith that the information and claims in the notice are accurate and complete.

3. Statement of Reasons (Article 17)

Where we remove or restrict visibility of a user's content, or suspend or terminate a user's account, based on illegality or a violation of our Acceptable Use Policy, Community Guidelines, or Terms of Service, we provide the affected user with a statement of reasons. That statement identifies: the specific content or conduct affected; the specific rule or law relied on; whether the decision was made using automated means; and the redress options available to the user, including the internal complaint process in Section 4 and, where applicable, the out-of-court dispute option in Section 5.

4. Internal Complaint-Handling

If you receive a statement of reasons and disagree with the decision, you can submit an internal complaint using the contact details in Section 12. We review the complaint, including any additional information you provide, and respond with the outcome. Submitting an internal complaint does not affect your ability to pursue the out-of-court option described in Section 5 or any other legal remedy available to you.

5. Out-of-Court Dispute Settlement

Under DSA Articles 20 and 21, users are entitled to select a certified out-of-court dispute settlement body to resolve disputes relating to content-moderation decisions, as an alternative to the internal complaint process or a court. VLStudio is a sole trader (autonomo) currently evaluating which certified out-of-court dispute settlement body to register with; a specific body is not yet named in this policy. This section will be updated once a body is selected and confirmed. In the meantime, the internal complaint process in Section 4 and the single point of contact in Section 6 remain available.

6. Single Point of Contact

Under DSA Articles 11 and 12, VLStudio designates a single point of contact for communications from Member State authorities, the Commission, the European Board for Digital Services, and directly from users, in relation to this policy:

• Email: [[CONTACT_EMAIL_LEGAL]], interim address: vlstudiopartners@hotmail.com
• Postal: Vladyslav Zhminko, Carrer de Valencia 191, 6.1, 08011, Barcelona, Spain

Because VLStudio is established in the EU (Spain), no separate Article 13 EU legal representative is required. A separate point of contact for UK regulatory purposes, if one becomes necessary given the UK user base, is tracked as [[UK_REPRESENTATIVE]] and will be added here once resolved.

7. Terms and Conditions Transparency (Article 14)

Under DSA Article 14, our terms and conditions on content restrictions must be set out in clear, plain, unambiguous, and user-friendly language, and be publicly available. VLStudio satisfies this obligation by cross-linking, rather than duplicating, the two documents that actually contain those content rules: our Acceptable Use Policy (the single, consolidated prohibited-content and prohibited-conduct list) and our Community Guidelines (how that list is applied at the point of posting, listing, or reviewing, and what our moderation actions mean in practice). Reading this policy together with those two is how the Article 14 transparency duty is met.

8. Transparency Reporting and Active-User Thresholds (Articles 15 & 24)

DSA Article 15 requires online platforms to publish periodic transparency reports on content-moderation activity, and DSA Article 24 requires publication of the average monthly active recipients of the service in the EU, a figure that determines whether a platform crosses the threshold (45 million average monthly active recipients in the EU) into "very large online platform" (VLOP) status, which triggers substantially heavier obligations. VLStudio's current user base is well below any such threshold today. We are monitoring this on an ongoing basis and will begin publishing periodic transparency reports and active-recipient figures as our scale and the applicable thresholds require, in line with our size as a sole-trader operated service.

9. UK Online Safety Act 2023: A Separate Regime

The UK Online Safety Act 2023 ("OSA") is a distinct legal regime from the EU DSA. Having a DSA-compliant notice-and-action process does not, by itself, satisfy the OSA. Where VLStudio's service is in scope of the OSA given its UK user base, the following duties apply separately:

• Illegal-content duties. A duty to take proportionate steps to prevent users from encountering priority illegal content, to minimize the length of time illegal content identified through a notice remains available, and to operate a notice-and-takedown process for illegal content specific to the UK regime, which VLStudio operates through the same reporting channel and contact details described in Sections 2 and 12 of this policy.
• Children's-risk-assessment duties. A duty to assess the risk that children could encounter content harmful to them on the service, and to put in place proportionate measures to mitigate and manage that risk, including age-assurance measures where appropriate. VLStudio does not yet have a completed OSA children's-risk assessment; this is tracked as an open item alongside the age-gate and minimum-age policy work described in our other legal documents, and this section will be updated once that assessment is completed.

Both sets of OSA duties are ongoing obligations owed to the UK regulator (Ofcom), not a one-time filing, and are reassessed as the service and its UK user base grow.

10. Current Enforcement Gap Affecting Both Regimes

11. Changes to This Policy

We may update this policy from time to time, including as the reporting-coverage and enforcement gaps described above are fixed, and as the out-of-court dispute body and UK point of contact are confirmed. When we make a material change, we update the "Last updated" date above.

12. Contact

To submit a notice about content, request a statement of reasons, file an internal complaint, or contact our single point of contact under the DSA or UK OSA:

• Email: [[CONTACT_EMAIL_LEGAL]], interim address: vlstudiopartners@hotmail.com
• Postal: Vladyslav Zhminko, Carrer de Valencia 191, 6.1, 08011, Barcelona, Spain