ADVERTISING & SPONSORED CONTENT POLICY
Last Updated: 7th of May 2026
1. Purpose, Scope and Regulatory Commitment
This Advertising & Sponsored Content Policy (the "Policy") establishes the legal and operational framework governing all forms of advertising, sponsored communications, branded integrations, commercial endorsements, and promotional activities on the JustQA platform (the "Platform"), operated by Nerqis Ltd, a company incorporated under the laws of the Republic of Cyprus (the "Company").
This Policy applies if and to the extent JustQA makes available advertising, sponsored content, commercial communications, brand partnerships, or similar promotional features on the Platform.
At present, JustQA does not display advertising and does not engage in behavioural, targeted, or advertising-based data processing. If this changes, this Policy will govern how such content is presented and managed, alongside the Privacy Policy and Terms and Conditions.
The purpose of this Policy is to ensure that all advertising and commercial communications on the Platform are transparent, lawful, fair, and compliant with applicable European Union and Cyprus legislation. Nothing in the Policy imposes a general obligation to monitor commercial communications.
This Policy applies to:
- Users of the Platform,
- Advertisers and sponsors,
- Affiliate partners,
- Agencies and intermediaries,
- Any third party engaging in commercial communications via the Platform.
This Policy forms an integral part of the Platform's Terms and Conditions, Copyright & Intellectual Property Policy, and Privacy Policy. In case of inconsistency, applicable law shall prevail.
2. Legal Framework and Compliance Standards
The Company operates in accordance with:
- Regulation (EU) 2022/2065 (Digital Services Act),
- Directive 2005/29/EC on unfair commercial practices,
- Regulation (EU) 2016/679 (GDPR),
- Directive 2002/58/EC (ePrivacy Directive),
- Cyprus Consumer Protection Law,
- Cyprus Data Protection Law,
- Applicable competition and advertising laws.
The Company is committed to ensuring that advertising practices on the Platform respect consumer transparency, do not mislead users, protect minors and vulnerable individuals, and comply with data protection requirements.
3. Definitions
For the purposes of this Policy:
"Advertising" means any form of commercial communication designed to directly or indirectly promote goods, services, brands, business interests, or causes. This includes display advertisements, promotional banners, sponsored listings, promoted recommendations, affiliate marketing links, paid search placements, influencer endorsements, and any other paid promotional format.
"Sponsored Content" means any content or communication that contains or incorporates any commercial communication for which monetary or non-monetary consideration has been provided to a user or third party. Consideration includes payments, commissions, free products, services, discounts, or any material benefit.
"Targeted Advertising" means advertising displayed based on profiling, behavioural analysis, inferred interests, demographic characteristics, or other user-specific parameters.
4. Fundamental Principles
All Advertising and Sponsored Content on the Platform must adhere to the following principles:
- Transparency, meaning that commercial communications must be clearly identifiable as such.
- Truthfulness, meaning that advertisements must not contain false or misleading claims.
- Fairness, meaning that commercial communications must not exploit vulnerable users or minors.
- Legality, meaning that advertisements must comply with applicable law.
- Accountability, meaning that advertisers remain responsible for the content and legality of commercial communications.
5. Advertising Transparency (Article 26 DSA Compliance)
Where the Platform displays Advertising, Users shall be clearly informed that the content constitutes an advertisement. Advertising shall be presented in a manner that is distinguishable from editorial or organic content.
Each advertisement shall clearly indicate the natural or legal person on whose behalf the advertisement is presented.
Where advertising is targeted based on profiling or user-specific parameters, the Platform shall provide meaningful information regarding the main parameters used to determine why a particular User received that advertisement. Such information shall be accessible in a clear and intelligible manner.
Advertising must not be disguised as user-generated content, editorial content, or platform-neutral recommendations.
Commercial communications shall not be presented in a manner that is deceptive, covert, or likely to mislead Users regarding their commercial nature.
Users shall have access to mechanisms enabling them to report advertisements or Sponsored Content that they reasonably believe violate this Policy, applicable law, or Platform rules. Reports may include complaints relating to misleading advertising, unlawful goods or services, undisclosed Sponsored Content, or violations of consumer protection law. The Company may review such reports and take appropriate action in accordance with this Policy.
6. Responsibilities for Sponsored Content
Any party who includes Sponsored Content, affiliate links, brand integrations, endorsements, or promotional references through the Platform must clearly and prominently disclose the commercial nature of such content.
Disclosures must be placed in a position and format that ensures visibility and comprehension by Users. Disclosures must not be hidden within metadata, obscure sections, or inaccessible descriptions.
Sponsored Content must comply with consumer protection laws, advertising standards, intellectual property rights, and sector-specific regulations.
No party shall make false, misleading, exaggerated, or unsubstantiated claims about products or services.
The Company reserves the right to require standardised disclosure wording, placement requirements, or additional transparency measures where appropriate.
Failure to provide adequate disclosure may result in removal of content or account suspension.
7. Platform-Delivered Advertising
Where the Company directly sells or delivers advertising space on the Platform, it shall ensure that:
- Advertisements are clearly identifiable as such.
- The advertiser is clearly identifiable.
- Advertisements comply with this Policy and applicable law.
The Company may conduct reasonable due diligence on advertisers and may reject, suspend, or remove advertising campaigns where legal, regulatory, reputational, or operational risks arise.
The Company retains full discretion over advertising placement, display, frequency, and format.
Advertising Review Procedures
The Company may implement internal review procedures for advertising campaigns prior to publication, including automated and manual review mechanisms intended to identify potential violations of applicable law or this Policy. Such procedures are implemented on a reasonable efforts basis and shall not constitute a general obligation to monitor advertisements.
Advertiser Verification
The Company may require advertisers to provide identification information, business registration details, or other verification materials prior to allowing advertising campaigns to be placed on the Platform.
8. Targeted Advertising and Data Protection
Where Advertising involves processing of personal data, including profiling, behavioural tracking, or targeted marketing, such processing shall comply with GDPR and applicable data protection laws.
Personal data shall only be processed for advertising purposes where a valid legal basis exists. Where required by law, explicit and informed user consent shall be obtained prior to the processing of personal data for personalised advertising.
Users shall be informed in the Privacy Policy of:
- The existence of profiling for advertising purposes,
- The categories of data used,
- The purposes of processing,
- Their rights to object, withdraw consent, or request restriction.
Sensitive personal data shall not be used for advertising purposes in violation of Article 9 GDPR.
Where required under the Digital Services Act, Users shall be provided with information explaining the main parameters used in determining targeted advertisements.
Users shall have access to mechanisms enabling them to manage advertising preferences where required by law.
9. Advertising to Minors and Vulnerable Persons
Advertising directed at minors shall comply with applicable child protection and consumer protection laws.
The Platform shall not engage in targeted advertising based on profiling where prohibited by applicable law, including where profiling is based on data of minors.
Advertisements shall not exploit the inexperience, vulnerability, or credulity of minors.
Content that promotes harmful body image, dangerous challenges, exploitative conduct, or age-inappropriate products shall not be permitted.
10. Prohibited Advertising Categories
10.1
The following categories of advertising are prohibited on the Platform:
- Advertising promoting illegal goods or services.
- Advertising relating to unlicensed gambling, financial scams, pyramid schemes, or fraudulent investment products.
- Advertising for prohibited medical claims or unapproved pharmaceuticals.
- Advertising that infringes intellectual property rights.
- Advertising promoting hate speech, discrimination, violence, or unlawful conduct.
- Advertising that violates sanctions or export control laws.
- Advertising that circumvents the Platform's authorised payment or subscription systems or directs Users to bypass authorised payment channels.
The Company may remove such advertising immediately and may report unlawful conduct to competent authorities.
10.2 Political and Issue-Based Advertising
Advertising relating to elections, political actors, public policy, or societal issues may be subject to additional transparency requirements, advertiser verification procedures, or restrictions where required by applicable law or deemed necessary to protect the integrity of the Platform.
11. Affiliate Marketing and External Links
Advertisers must not use advertising, sponsored content, profile descriptions, links, or calls to action to direct, solicit, or encourage Users to make payments or transactions outside the authorised channels of the Platform. This includes the use of external payment links, QR codes, wallet addresses, bank details, private contact details, or other off-platform arrangements intended to bypass the Platform's authorised transaction mechanisms.
12. Enforcement and Sanctions
Without prejudice to any rights or remedies available under applicable law, violations of this Policy may result in proportionate enforcement measures, including removal of advertising material, account suspension, termination of agreements, or referral to competent authorities.
Repeated or serious violations may result in permanent removal from the Platform.
The Company may act without prior notice where immediate action is necessary to mitigate legal, regulatory, or reputational risks.
Proportionate Enforcement:
Enforcement measures under this Policy shall be applied in a proportionate manner, taking into account the nature and severity of the violation, potential harm to Users, and the prior conduct of the advertiser.
13. Cooperation with Authorities
Where required by law, the Company may cooperate with judicial, regulatory, or law enforcement authorities in relation to advertising practices that violate applicable legislation.
This may include preservation or disclosure of relevant information in accordance with data protection laws.
14. Transparency Reporting
Where applicable under the Digital Services Act, aggregated information relating to advertising moderation, enforcement actions, and compliance measures may be included in the Company's annual transparency report.
The Company shall not disclose confidential business information, trade secrets, or personal data beyond what is legally required.
15. Relationship with the Company
This Policy does not create a partnership, joint venture, or fiduciary relationship between advertisers and the Company.
16. Amendments
The Company reserves the right to amend this Policy to reflect changes in law, regulatory guidance, advertising technology, or business practices.
Material changes shall be communicated where required by applicable law. Continued use of the Platform following amendments constitutes acceptance of the revised Policy.