Moderation & Enforcement Policy

This policy explains how vaicat B.V. moderates content on the CUEBES platform, the actions we may take when content or behaviour breaks the rules, and your rights to a reasoned decision and an appeal under EU law. The substantive rules — what is permitted, what is prohibited — live in the Community Guidelines. The use of AI inside our moderation workflow is documented in the AI Use & Transparency Policy.

1. Core Principles

• Lawfulness: all actions comply with EU and national law.
• Proportionality: the response matches the severity of the violation.
• Transparency: users receive clear notification of any action and its reasons.
• Fairness: consistent, human-centred decision-making with human review of every significant restriction.

2. Reportable Content

2.1 What We Review

• User-generated content (posts, CUEs, comments, messages, code in public Codicles, research outputs, videos)
• Profile information and images
• Feature usage patterns (e.g. spammy posting, coordinated inauthentic behaviour)
• Technical behaviour (automation, scraping, abuse of APIs)

2.2 How Content Is Flagged

• User reports: via the in-product report tools or abuse@vaicat.com
• Formal complaints (DSA Art. 24): via /help/complaint
• Automated detection: systems flagging potential violations for human review
• Legal obligations: orders or notices from a competent authority
• Trusted flaggers: reports from entities designated under DSA Art. 22 receive priority review

3. Review Process

3.1 Submitting a Report

Reports can be submitted through the in-product report tools or by emailing abuse@vaicat.com. Include the location of the content (URL or description), the reason for the report, and any additional context.

3.2 Review Methodology

Trained reviewers and automated systems (with human oversight) assess the reported content against:

• Applicable law, especially illegal content under EU and national rules
• The Terms of Service
• The Community Guidelines
• Context and intent
• Account history

3.3 Timelines

• Illegal content reports: priority / expedited review
• Standard reports: 5–10 business days
• Appeals: 10–15 business days for our decision

4. Enforcement Actions

Actions are proportionate to violation severity:

• Minor: warning, request to edit content
• Moderate: content removal, visibility restriction (reach reduction)
• Serious: feature limitation (e.g. messaging, posting, recruiter access), temporary suspension
• Severe: account termination, referral to law enforcement

For repeat or coordinated violations, we may also restrict associated accounts, devices, or networks where there is a clear factual basis to do so.

5. Statement of Reasons (DSA Art. 17)

When we take action on content or an account, we provide a statement of reasons containing:

• Action taken: what we did (removal, restriction, suspension, etc.)
• Factual circumstances: what content or behaviour triggered the review
• Applicable rules: which policy provision or law was violated
• Reasoning: how we reached our decision, including the relevance of context and intent
• Appeal procedures: how to challenge the decision and the deadline (6 months)
• Automation disclosure: whether automated tools were used in detection or in the decision itself

6. Appeals & Redress

6.1 Internal Appeals

You may appeal any moderation decision within 6 months of receiving the statement of reasons. To submit an appeal:

• Use the in-product appeals tool, where available
• Or email abuse@vaicat.com with subject "Appeal — <decision reference>"
• Explain why you believe the decision was incorrect
• Provide any additional context or evidence

6.2 Appeal Review

• Appeals are reviewed by qualified personnel not involved in the original decision
• We aim to complete the review within 10–15 business days
• You will receive a reasoned decision; if we uphold the original action, the statement of reasons will explain why

6.3 Out-of-Court Resolution (DSA Art. 21)

If you disagree with our appeal decision, you may access:

• Certified DSA Dispute Bodies: EU-certified out-of-court dispute-settlement bodies under DSA Art. 21
• National authority: Autoriteit Consument & Markt (ACM) — www.acm.nl
• Courts: the courts of The Hague (governing law: the Netherlands), as set out in the Terms of Service §21

7. Automation Safeguards

7.1 Where We Use Automation

• Spam and malware detection
• Fraud prevention
• Illegal-content identification (CSAM, terrorism, etc.)
• Pattern recognition for policy violations and coordinated inauthentic behaviour

7.2 Human Oversight

A human reviews the decision before:

• Account terminations
• Significant account restrictions (long-term suspensions, recruiter delicensing)
• Complex or borderline content decisions
• Any appeal of an automated decision

See the AI Use & Transparency Policy §6 for the full automation framework.

8. EUnify Community Notes

EUnify allows users to submit community notes and corrections about institutions and programmes. These follow a dedicated review pipeline:

1. Submission: the user submits a note or correction
2. Queue: the submission enters the moderation queue
3. Review: a moderator evaluates against accuracy, relevance, Community Guidelines, and tone
4. Decision: approve, request changes, or reject (with reasoning)
5. Notification: the user is informed of the outcome
6. Publication: approved content goes live

EUnify community notes are typically reviewed within 5–10 business days. The same appeal rights apply.

Operator

• vaicat B.V.
• Noordeinde 99B, 2514 GD The Hague, Netherlands
• KvK (Dutch Trade Register): 89360672
• Email: abuse@vaicat.com