COMPLAINT & APPEALS POLICY
Last Updated: 7th of May 2026
1. Purpose and Scope
This Complaint & Appeals Policy (the "Policy") sets out the procedures governing the submission, assessment, resolution, and review of complaints relating to content, conduct, account actions, and moderation decisions 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 to Users, intellectual property rights holders, public authorities, and any third party who wishes to report alleged illegal activity, infringing material, or violations of the Platform's Terms and Conditions or applicable law.
This Policy forms an integral part of the Platform's contractual framework and must be read together with the Terms and Conditions and Copyright and Intellectual Property Policy. In the event of inconsistency, the Terms and Conditions shall prevail.
2. Platform Status and Regulatory Position
The Company operates as an online platform and hosting service provider within the meaning of Regulation (EU) 2022/2065 (Digital Services Act). The Company stores User data and provides AI-powered services but does not exercise general monitoring obligations and is not required to actively seek facts or circumstances indicating illegal activity.
In accordance with Article 8 of the Digital Services Act and the E-Commerce Directive, the Company is not subject to a general obligation to monitor information transmitted or stored. However, upon obtaining actual knowledge of illegal content or becoming aware of facts or circumstances from which illegality is apparent, the Company shall act expeditiously and proportionately to remove or disable access to such content.
3. Single Points of Contact
In accordance with Articles 11 and 12 of the Digital Services Act, the Company designates a single electronic point of contact for competent authorities and a single electronic point of contact for Users and complainants in the email address [email protected]. These contact details are clearly published on the Platform and may be used for the submission of notices, complaints, and regulatory communications. Communications may be submitted electronically and shall be processed in accordance with this Policy.
4. Types of Complaints Covered
This Policy governs complaints relating to alleged illegal content, including but not limited to copyright infringement, trademark infringement, unlawful distribution of protected works, defamation, privacy violations, hate speech, terrorist content, child exploitation material, and other unlawful content under European Union or national law.
It also applies to complaints concerning violations of the Platform's Terms and Conditions, account suspensions or terminations, restrictions on service access, impersonation, fraud, technical circumvention of protective measures, misuse of reporting mechanisms, and repeated violations.
Consumer refund disputes are governed separately by the Platform's Terms and Conditions and are not addressed in this Policy.
5. Submission of Notices of Alleged Illegal or Infringing Content
Any individual or entity who considers that content available on the Platform constitutes illegal content may submit a notice to the Company through the designated electronic reporting mechanism.
In accordance with Article 16 of the Digital Services Act, a notice shall be considered valid where it is sufficiently precise and adequately substantiated to enable the Company to identify the content concerned and assess the alleged illegality. To satisfy this standard, the notice must clearly identify the specific content at issue and its exact location on the Platform, provide a reasoned explanation of why the content is considered illegal, include the name and electronic contact details of the complainant, and contain a statement confirming a good faith belief that the information provided is accurate and complete.
Where the notice concerns intellectual property infringement, the complainant must confirm that they are the rights holder or duly authorised to act on behalf of the rights holder. The Company may request additional documentation where reasonably necessary to verify ownership, authority, or substantiation.
Notices that are manifestly unfounded, incomplete, abusive, automated in bad faith, or lacking sufficient substantiation may be rejected.
6. Assessment and Moderation Procedure
Upon receipt of a sufficiently precise and adequately substantiated notice, the Company shall assess the information in a timely, diligent, objective, and non-arbitrary manner. The complexity of the allegation, the seriousness of the potential harm, and the risk to Users or third parties may influence the speed and depth of the review.
The Company may use a combination of human moderators and technological tools to assist in identifying and evaluating allegedly unlawful content. Automated systems may assist in prioritising and detecting high-risk material, including through keyword analysis, metadata assessment, and hash-matching technologies. However, final decisions involving contested or complex assessments shall involve human oversight.
Depending on the circumstances, the Company may remove content, disable access to it, issue warnings, temporarily suspend accounts, permanently terminate accounts, or report unlawful conduct to competent authorities. Measures taken shall be proportionate to the severity, frequency, and nature of the violation.
Where immediate action is necessary to mitigate legal, regulatory, security, or safety risks, the Company may act without prior notice to the affected party.
7. Communication of Decisions
Where action is taken in response to a notice, the Company shall inform the complainant of the outcome. The affected User shall also be informed of the action taken, the legal or contractual basis for the decision, and any available complaint or appeal mechanisms.
Where required under applicable law, the Company shall provide a statement of reasons outlining the basis for the decision, the type of restriction imposed, and the available avenues for redress.
The Company is not required to disclose confidential information, personal data of third parties, trade secrets, or information that would compromise security or ongoing investigations. Complainant identity may be shared with the affected User where necessary for defence of legal claims, subject to GDPR.
8. Internal Complaint-Handling Mechanism
In accordance with Article 20 of the Digital Services Act, the Company maintains an internal complaint-handling system enabling Users to challenge account or moderation decisions.
An appeal may be submitted electronically within six months from notification of the relevant decision. The complaint must clearly identify the contested decision and provide a reasoned explanation of the grounds for challenge, together with any supporting evidence.
Appeals shall be reviewed by a human moderator who was not directly involved in the initial decision where reasonably possible. The review shall be conducted in a timely, diligent, objective, and non-discriminatory manner and shall be free of charge.
Following review, the Company shall notify the appellant of the outcome and provide a statement of reasons where required under applicable law. The outcome may confirm, reverse, or modify the original decision.
9. Out-of-Court Dispute Settlement
Without prejudice to the right to seek judicial redress before competent courts, Users may have the right to select a certified out-of-court dispute settlement body in accordance with Article 21 of the Digital Services Act, where such bodies are available under applicable law.
Participation in out-of-court dispute settlement procedures does not limit the right of either party to initiate court proceedings.
10. Repeat Infringement and Abuse of the Complaint System
The Company maintains a repeat violation policy. A User may be deemed a repeat violator where multiple substantiated notices of infringement or terms violations are received, or where there is a demonstrated pattern of non-compliant conduct.
In appropriate circumstances, repeat violations may result in permanent account termination.
The Company also reserves the right to restrict reporting privileges or take appropriate action against parties who submit knowingly false, malicious, or abusive notices. Submission of fraudulent or bad-faith complaints may expose the complainant to liability under applicable law.
11. Record-Keeping and Transparency
The Company may maintain records of notices received, actions taken, appeals submitted, and outcomes of review for compliance, audit, legal defence, and regulatory reporting purposes.
Aggregated and anonymised information relating to moderation activity may be included in the Company's annual transparency report in accordance with Article 15 of the Digital Services Act.
Records shall be retained only for as long as necessary to comply with legal, regulatory, and evidentiary obligations.
12. Cooperation with Authorities
Where required by law or where serious criminal conduct is identified, the Company may cooperate with judicial, regulatory, or law enforcement authorities. This may include the preservation of relevant information and disclosure pursuant to lawful requests, subject to compliance with applicable data protection laws.
13. Data Protection and Confidentiality
Personal data submitted in connection with complaints shall be processed in accordance with the Platform's Privacy Policy and applicable data protection legislation, including the GDPR. Data may be shared with affected parties to the extent necessary for resolution of the complaint and in compliance with legal obligations.
14. Amendments to this Policy
The Company reserves the right to amend this Policy to reflect changes in law, regulatory guidance, operational practices, or Platform functionality. Material changes shall be communicated where required by applicable law. Continued use of the Platform constitutes acceptance of the revised Policy.