Six Vibes — DSA Moderation & Transparency Policy

Draft — this document is under legal review and may change before launch.

Effective date: [EFFECTIVE DATE]

This policy explains how Six Vibes moderates content and accounts, in line with the EU Digital Services Act (Regulation (EU) 2022/2065, "DSA"). Six Vibes is an online platform operated by [OPERATOR NAME], [ADDRESS], [KVK/registration number if any]. Six Vibes is a micro/small enterprise under the DSA; some obligations (e.g. Art. 20–24 for online platforms) may therefore apply in reduced form [lawyer to confirm which exemptions apply — Art. 19 exempts micro and small enterprises from Section 3 obligations, but Art. 16 and 17 apply to all hosting services]. We nevertheless apply the measures below voluntarily.

1. Points of contact (Art. 11 and 12)

• Users: in-app Report button, or info@sixvibes.org
• Member State authorities, the Commission and the Board: info@sixvibes.org — subject "DSA authority"
• Languages: English and Dutch.

We have no legal representative in the EU because we are established in the Netherlands.

2. What we moderate

We moderate against (a) illegal content under EU or Member State law, and (b) content and behaviour that breaks our Terms of Service and Community Guidelines. What users may post is already restricted by design:

• Messages: text only, max 200 characters, links are rejected by the server.
• Profiles: display name (max 40), bio (max 300), vibes, up to 6 photos.
• Plans: a place, date/time window, vibes.
• Shared activity plans: generated by our server, with links only to websites returned by the AI's own web search and only over https; tapping a link shows the domain and asks for confirmation.

3. Proactive moderation of photos

• Every uploaded photo is checked by an automated vision model (Hive) before it can be seen by anyone.
• The model screens for nudity/explicit content, violence and signs of a minor.
• Photos with no flags above the threshold are approved automatically. Anything flagged is held (not visible) and reviewed by a human, who approves or rejects it. Our rule is "when in doubt, reject."
• Only approved photos can become your profile picture or your face on the map.
• If the moderation service is unavailable, the photo stays held (fails closed).

4. Notice and action (Art. 16)

How to notify us

• In the app: every profile and every message has a Report button. Choose a reason: Spam, Harassment or abuse, Inappropriate photos, Suspected minor, Something else. The specific message is attached automatically when you report from a chat.
• By email (including if you are not a user): info@sixvibes.org with subject "Notice". Please include: (1) why you think the content is illegal or breaks our rules; (2) enough information to find it (the user's display name, a screenshot, roughly when/where); (3) your name and email (not required for notices about child sexual abuse material); (4) a statement that you believe in good faith the notice is accurate and complete.

What we do

1. Acknowledgement: we confirm receipt (in-app reports show an immediate confirmation; email notices get a reply, normally within 2 working days).
2. Priority: reports marked Suspected minor are flagged urgent, sorted to the top and acted on immediately — the account is suspended pending review, never left in a queue. Credible threats to life or safety are treated the same way.
3. Review: a human (the operator) reviews every report. Target: within 24 hours; urgent reports as soon as seen.
4. Decision: dismiss, remove content, or suspend/terminate the account. The decision and a written reason are recorded.
5. Feedback to the notifier: we inform the person who reported of the decision, without identifying details of the other party.

Where we become aware of information giving rise to a suspicion of a criminal offence involving a threat to the life or safety of a person, we inform the competent law-enforcement authorities (Art. 18). Suspected child sexual abuse material is reported to the relevant authorities / hotline [e.g. Offlimits (NL) / INHOPE member].

5. Measures we may take

Measures are proportionate to the seriousness, frequency and intent of the breach. We also suspend, after a warning, users who frequently submit manifestly unfounded reports or complaints (Art. 23).

6. Statement of reasons (Art. 17)

When we remove your content or restrict, suspend or terminate your account, we will tell you (by email or in the app) — unless the content was spam or a legal reason prevents us — including:

• what we decided and its scope and duration;
• the facts and circumstances relied on, including whether it came from a report or our own detection;
• whether automated means were used (e.g. photo moderation) in detecting or deciding;
• the legal ground (if illegal content) or the rule in our Terms/Guidelines that was broken;
• how you can appeal (section 7) and other routes (section 8).

7. Internal complaint handling — appeals (Art. 20)

• You can appeal any moderation decision, and the decision on a report you made, free of charge within 6 months of the decision.
• Email info@sixvibes.org with subject "Appeal", from the email address on your account, explaining why you think the decision was wrong.
• The appeal is reviewed by a human, not solely by automated means, and decided without undue delay (target: within 14 days).
• If we agree, we reverse the decision (e.g. restore the photo or lift the suspension). Either way we give you a reasoned answer and tell you about out-of-court dispute settlement.

8. Out-of-court dispute settlement (Art. 21) and courts

If you disagree with our decision or appeal outcome, you can refer the dispute to an out-of-court dispute settlement body certified by a Digital Services Coordinator. A list is published by the European Commission. In the Netherlands the Digital Services Coordinator is the Autoriteit Consument & Markt (ACM). You can always also go to court. We engage in good faith with certified bodies.

9. Use of automated tools

• Automated photo moderation (Hive) — described in section 3. Automated tools never reject a photo or suspend an account on their own; they only approve clean photos or hold photos for human review.
• Automated age estimation at sign-up (provider: Didit). Users who fail can request a human review at info@sixvibes.org.
• Server-side rules reject links in messages and enforce length limits.

10. Recommender systems (Art. 27)

Six Vibes does not rank or recommend content algorithmically. Who you see is determined only by transparent parameters: the map area you are looking at (Now) or the place and time of your plan (Later, minimum 1 hour overlap, within roughly 5 km), shared vibes, and mutual gender / interested-in settings. You can influence this by changing your vibes, your interested-in settings, your plans, or by turning on Incognito.

11. Advertising

There is no advertising on Six Vibes (Art. 26 and 28 — no profiling-based ads, none to minors).

12. Transparency reporting (Art. 15)

We publish a transparency report at least once a year at sixvibes.org/transparency [or in the legal storage bucket], covering:

• number of notices received, by reason, and the median time to act;
• number of orders from authorities, by type, and median response time;
• number of own-initiative moderation actions (including photos held/rejected), by type;
• use of automated tools, with indicators of accuracy (e.g. share of auto-flagged photos approved by a human);
• number of appeals, their basis, outcomes and median handling time;
• number of suspensions (including for misuse);
• number of disputes submitted to out-of-court bodies and their outcomes;
• average monthly active recipients in the EU (Art. 24(2)), published every six months.

[Lawyer to confirm: micro/small enterprises are exempt from Art. 15 and Section 3 reporting, but publishing a simple report is recommended practice.]

13. Records

We keep reports, decisions, statements of reasons and appeals for the periods in our Data Retention Schedule, to evidence compliance and handle appeals and legal claims.

Contact: info@sixvibes.org