Reports and Moderation Policy

Informational translation. The legally binding version is the Spanish original, available at /legal/denuncias.html. In case of discrepancy, the Spanish version shall prevail.

1. Scope

This Policy establishes the procedure by which any natural or legal person may notify ITRION SOFTWARE, S.L. of the existence of content or conduct in the ULOX Service that is allegedly illegal or contrary to the Terms and the Community Rules, as well as the review and, where appropriate, appeal procedure.

This mechanism complies with the notice-and-action requirements set out in Regulation (EU) 2022/2065 on Digital Services (the "Digital Services Act" or "DSA") and is also applied to users outside the EU as a voluntary standard.

2. Technical limits arising from encryption

ITRION provides an end-to-end encrypted service and client-side encrypted storage. This implies that:

• ITRION cannot inspect a priori the content of communications or content stored by users.
• ITRION does not perform proactive moderation of encrypted content, except for technical verification of what is visible (public metadata, infrastructure abuse, traffic patterns).
• Effective reports require the reporter to provide reasonable evidence of the content or conduct reported, since ITRION cannot obtain it unilaterally.

3. Reporting channels

Three channels are made available:

3.1. In the application

When available, the user may use the integrated reporting functionality in the application (report button on a message, contact or group). This functionality allows the reporter to provide the minimum data and, optionally, a copy of the reported content decrypted on the client.

3.2. By email

For general reports: abuse@ulox.org.

For formal requests from authorities: law-enforcement@ulox.org.

3.3. By post

ITRION SOFTWARE, S.L. — "Trust & Safety ULOX", Calle Francisco Silvela, 110, floor 2, 28028 Madrid, Spain.

4. Minimum content of the report

For the report to be processed effectively, it must contain at least:

• Identification of the reporter: name or pseudonym, contact details (email address to which ITRION can respond). Anonymous reports are accepted but may have limited processing.
• Description of the reported content or conduct with sufficient specificity.
• Location in the Service: ULOX ID of the alleged infringer, group identifiers, approximate date and time, or any other data that allows identification of the reported material.
• Reason for the report: why the reporter considers the content to be illegal or to infringe the Rules.
• Good faith declaration: reporter's statement that the information provided is true and complete to the best of their knowledge.
• Evidence, where possible: screenshots, copy of the reported content, links or other evidence.

5. Acknowledgement of receipt

ITRION will acknowledge receipt of all reports received by email, within a reasonable period and, save for justified cause, not exceeding seventy-two (72) business hours. Acknowledgement of receipt does not imply recognition of the merits of the report.

6. Evaluation and decision

ITRION will evaluate the report diligently, objectively and in a non-arbitrary manner. The decision will be based on the Terms, the Community Rules, applicable legislation and, where appropriate, recommendations from competent authorities.

The response time will depend on the complexity and severity of the report. As a reference:

Type of report	Indicative response time
Imminent risk to life or integrity (credible threats, self-harm, terrorism)	Immediate action; substantive response within ≤ 24 h
CSAM, harm to minors, manifestly illegal content	Immediate action; substantive response within ≤ 24 h
Harassment, non-imminent threats, ordinary illegal content	≤ 7 calendar days
Intellectual property, civil reports	≤ 14 calendar days
Other	≤ 30 calendar days

7. Measures that may be taken

After evaluation, ITRION may adopt one or more of the measures provided in the Community Rules, including account cancellation and cooperation with authorities, in accordance with the principle of proportionality.

8. Reasoning of decisions

When ITRION adopts a restrictive measure against a user (suspension, cancellation, feature restriction), it will communicate to the affected user, by the technical means available, a clear and specific statement of reasons including:

• The measure adopted and its temporal scope.
• The facts and circumstances on which it is based.
• Reference to the rule or term infringed.
• The possibility of appeal and channels to exercise it.

9. Appeal procedure

The user affected by a measure may submit a free internal appeal within six (6) months of notification of the decision. The appeal must be addressed to abuse@ulox.org stating:

• Identification of the user and the appealed measure.
• Reasons for the appeal: facts, evidence, arguments.
• Relief sought: reactivation, partial lifting, etc.

ITRION will resolve the appeal within a reasonable period, generally not exceeding thirty (30) calendar days. The resolution of the appeal will be reasoned and will be undertaken by personnel other than those who took the initial decision whenever organisationally feasible.

10. Out-of-court dispute resolution

Without prejudice to the right to go to court, users resident in the EU may select an out-of-court dispute resolution body certified under Article 21 of the DSA. ITRION will cooperate in good faith with the chosen body, without prejudice to its right to present its allegations and evidence.

11. Cooperation with authorities

ITRION cooperates with competent judicial and administrative authorities and with legally empowered law enforcement bodies. Formal requests are channelled through law-enforcement@ulox.org and must be accompanied by the applicable legal grounds.

ITRION delivers the data it actually holds and provides the technical assistance that is reasonably possible. The cryptographic model of the Service, in accordance with the privacy-by-design principle, means that user encryption keys are not held by ITRION; this limitation is recorded in good faith in each response without ever implying a refusal to cooperate.

12. Malicious or repeated reports

Reports submitted in manifest bad faith (false, repeatedly unfounded, with harassment purposes) shall be deemed not submitted and may give rise to measures against the reporter, including suspension of their reporting capacity and, where appropriate, cancellation of their account.

13. Transparency reports

ITRION will prepare and publish periodic transparency reports with aggregated data on reports received, measures adopted and authority requests, in accordance with the DSA's transparency obligations and other applicable regulations.

14. Single point of contact

For the purposes of Articles 11 and 12 of the DSA, ITRION designates the following single points of contact:

• For authorities: law-enforcement@ulox.org (languages: Spanish, English).
• For Service recipients (users): abuse@ulox.org (languages: Spanish, English).