Content Moderation Policy
How content on LeraLink is moderated, who decides, which tools are used, and how to report content or challenge a decision.
Last updated: 12 November 2026
1. About this policy
LeraLink is provided by SSStudio, The Hague, the Netherlands, trading as LeraLink, registered with the Dutch Chamber of Commerce (KvK) under number 98779885, VAT identification number (BTW-ID) NL005352396B67. Postal address on request: legal@lera.link. Company Information gives our full details. LeraLink stores and publishes content at the request of the organisations and people who use it. It is therefore a hosting service within the meaning of the Digital Services Act (Regulation (EU) 2022/2065, the "DSA").
This policy gives the information that article 14(1) of the DSA requires about restrictions on content and about our content moderation: our policies, procedures, measures and tools, including automated tools and human review, and how our internal complaint handling works. It applies alongside the Terms of Service and the Customer Agreement.
What is and is not allowed is set out in the Acceptable Use Policy. This policy describes how we enforce it.
2. What we moderate and on which grounds
We moderate content on two separate grounds. Every decision states which ground it rests on.
| Ground | What it means | Examples |
|---|---|---|
| Illegal content | The content does not comply with the law of the European Union or of an EU Member State (DSA art. 3(h)). | Child sexual abuse material, terrorist content, unlawful hate speech, defamation, infringement of intellectual property, doxing. |
| Incompatibility with our terms | The content or conduct is lawful but breaks the Terms of Service, the Acceptable Use Policy or the Customer Agreement. | Spam, impersonation, malware links, misuse of AI features, adding people to a newsletter who are not the installation's members or subscribers. |
"Content" means anything stored on LeraLink: Pieces in every language and version, files, images, audio, data, comments, annotations, reviews, profiles, newsletters, event pages and messages.
Where content is illegal only in some Member States, a measure may be limited to those Member States, and the statement of reasons says so.
3. Who moderates
3.1 SSStudio, for the platform
SSStudio decides on notices sent to us and on any content anywhere on LeraLink that may be illegal or break our terms. SSStudio also decides on measures against accounts and installations.
Today one person, the owner of SSStudio, operates LeraLink. Notices are handled by that person in English or Dutch; Persian is also possible.
3.2 Installation owners and administrators, within their installation
Each installation is run by a customer that decides who may join, what its people may do and what is published there. Its owners and administrators, and the editors and moderators they appoint, may moderate content in their installation: for example, hide or remove a comment, decline a submission, restrict a Piece to members, or remove a member.
They do so under their own community rules, which must be consistent with the Terms of Service and the Acceptable Use Policy. They may be stricter than our rules; they may not allow what our rules prohibit. Where an installation provides a service to its own members, the customer may have its own obligations under the DSA or other law, where those apply to it.
A decision taken by an installation's administrators is that installation's decision. A person who disagrees with it should first raise it with the installation. If the person believes the content concerned is illegal, or that the installation is using LeraLink in breach of our terms, they can report it to us (section 6).
3.3 How the two levels interact
When we receive a notice about content in a customer's installation:
- We assess the notice ourselves.
- Where the content is manifestly illegal, where there is a risk to anyone's life or safety, or where the law requires us to act, we act directly and inform the installation's owners.
- In other cases we may inform the installation's owners and give them a short period to act. We remain responsible for a timely decision on the notice and decide ourselves if the installation does not act.
4. Tools we use
4.1 Human review of every decision
Every decision to remove content, disable access to it, restrict its visibility, or suspend or terminate an account or installation is taken by a person, after reviewing the content and its context.
4.2 Automated tools
We use automated tools only for:
- Rate limiting: limits on how often an address or account can request sign-in codes, submit forms, and write or report margin notes. Requests above a limit are refused.
- Sign-up protection: an installation can be open to new members, require approval, or accept new members only by invitation. When unusually many new people join an open installation in a short time, the platform automatically switches it to approval and holds the memberships of that period that have no role above a reader's until a person approves them; the installation's owners and administrators, and we, are told at once. New members have tighter limits on writing in the margin during their first hours. An address at an email domain that cannot receive mail, or that is on our list of blocked domains, cannot be used to join.
- Contact form checks: a hidden field, limits per address, and a check that the sender's domain can receive email. A message that fails them is refused or not delivered. A human check (Cloudflare Turnstile) can be switched on for an installation's forms.
- Network protection: Cloudflare's protection of its network, which can block traffic that looks like an attack.
No automated tool removes or disables content, restricts its visibility, or suspends or terminates an account. A membership held by sign-up protection keeps its account and can still read; a person approves or refuses it. Where a decision on content followed an automated signal, the statement of reasons says so.
We do not use AI models to moderate content. The AI features of LeraLink are described in How LeraLink Uses AI.
5. Measures we can take
| Measure | Effect |
|---|---|
| Removal | The content is deleted from the installation. |
| Disabling access | The content is kept but cannot be read by anyone except, where appropriate, its author and the installation's administrators. Used where content must be preserved, for example for an investigation or a complaint. |
| Restricting visibility | The content remains, but is shown to fewer people: for example only to members, or not in feeds, newsletters or search. |
| Restricting features | An account or installation loses the use of a feature, for example commenting, sending newsletters or using AI features. |
| Suspension of an account | The account cannot be used for a stated period. |
| Termination of an account | The account is closed. |
| Suspension or termination of an installation | Under the Customer Agreement, as a last resort. |
LeraLink does not offer monetisation of content to users, so the suspension or termination of monetary payments does not apply.
How we choose between measures is set out in the enforcement section of the Acceptable Use Policy.
6. Notice and action
6.1 How to send a notice
Anyone can notify us of content they believe is illegal, using:
- an email to legal@lera.link with the subject line Content report, as the Report Content page describes.
Under article 16(2) of the DSA, a notice should contain:
- a sufficiently substantiated explanation of why you believe the content is illegal;
- the exact electronic location of the content, such as its web address, and where needed further information to identify it;
- your name and email address, except for notices about child sexual abuse material, where you may stay anonymous; and
- a statement that you believe in good faith that the information and allegations in the notice are accurate and complete.
A notice that contains these elements, and that allows a diligent provider to establish the illegality without a detailed legal examination, gives us actual knowledge of the content. Notices about breaches of our terms that are not illegal can be sent in the same way.
6.2 What we do with a notice
- Confirmation of receipt. If you gave an email address, we confirm receipt without undue delay.
- Assessment. We process every notice in a timely, diligent, non-arbitrary and objective manner. We aim to decide without undue delay. Notices about child sexual abuse material, terrorist content and threats to life or safety are handled first.
- Decision. We tell you our decision without undue delay, with information on how you can seek redress.
- The person concerned. If we take a measure, we give the person who provided the content a statement of reasons (section 7).
If a notice concerns content in a customer's installation, we may share the notice with that installation's owners. We share the notifier's name and email address only where strictly necessary, for example for a claim of infringement of intellectual property, and we tell the notifier in advance.
7. Statements of reasons
When we remove content, disable access to it, restrict its visibility, restrict features, or suspend or terminate an account or installation, we give the person concerned a clear and specific statement of reasons, as article 17 of the DSA requires, unless we have no electronic contact details for that person. A statement of reasons contains:
- which measure we took, and where relevant its territorial scope and duration;
- the facts and circumstances on which the decision rests, including whether it followed a notice and, where strictly necessary, the identity of the notifier;
- whether automated means were used, and whether the decision concerned content found or identified by automated means;
- where the decision concerns illegal content, the legal ground relied on and why the content is considered illegal on that ground;
- where the decision concerns incompatibility with our terms, the provision of the Terms of Service, the Acceptable Use Policy or the Customer Agreement relied on and why the content is considered incompatible with it; and
- the ways to seek redress: our internal complaint procedure, out-of-court dispute settlement, and the courts.
We do not give a statement of reasons where a competent authority has ordered us not to inform the person, for as long as that order applies.
8. Complaints about our decisions
8.1 Internal complaint
If we took a decision about your content or account, or decided not to act on your notice, you can complain to us free of charge:
- How: reply to the decision email, or write to legal@lera.link, stating which decision you disagree with and why.
- When: at any time within six months from the day you were informed of the decision.
- Review: the decision is reviewed afresh, on the basis of your complaint and any new information.
- Outcome: we reverse the decision without undue delay if the complaint shows that the content was not illegal or not in breach of our terms, or that the measure was disproportionate. We tell you the outcome and the reasons, and the further ways to seek redress.
8.2 Who reviews a complaint
A complaint is reviewed by someone other than the person who took the original decision wherever possible. Because one person operates LeraLink today, this is not always possible internally. Where it is not, the operator reviews the decision afresh, and the reply says that the review was carried out by the same person who took the original decision.
The final decision on a complaint is always taken by a person, never by automated means.
8.3 Out-of-court dispute settlement and courts
You may also take a dispute about a moderation decision to an out-of-court dispute settlement body certified under article 21 of the DSA. The European Commission publishes a list of certified bodies. We engage with such a body in good faith, to the extent article 21 applies to us. Using our internal complaint procedure is not a precondition.
You can at any time bring the matter before a competent court, as set out in the Terms of Service. Consumers keep the right to go to the court of their place of residence where the law gives them that right.
You can also lodge a complaint about our compliance with the DSA with the Digital Services Coordinator of the Member State where you live or are established. In the Netherlands this is the Autoriteit Consument & Markt (ACM).
9. Orders from authorities
9.1 Orders to act against illegal content (DSA art. 9)
When we receive an order from a competent judicial or administrative authority to act against illegal content, we inform the authority without undue delay of the effect we gave to it, specifying if and when. We inform the person who provided the content of the order, our action and the possibilities for redress, at the latest when we act, unless the authority asks us not to.
Removal orders for terrorist content under Regulation (EU) 2021/784 are acted on within one hour of receipt, as that Regulation requires. Orders may come, among others, from the Dutch authority for online terrorist and child sexual abuse material (Autoriteit online Terroristisch en Kinderpornografisch Materiaal, ATKM).
9.2 Orders to provide information (DSA art. 10)
When we receive an order from a competent authority to provide information about specific users, we check that it meets the conditions of article 10 of the DSA and of the applicable law, provide only the information ordered, inform the authority of the effect we gave to it, and inform the person concerned, unless the authority asks us not to.
9.3 Where to send orders
Authorities send orders to legal@lera.link, our single point of contact under articles 11 and 12 of the DSA. We accept orders in English and Dutch.
10. Suspected criminal offences threatening life or safety (DSA art. 18)
If we become aware of information that gives rise to a suspicion that a criminal offence involving a threat to the life or safety of a person or persons has taken place, is taking place or is likely to take place, we promptly inform the law enforcement or judicial authorities of the Member State concerned and provide all relevant information available. In the Netherlands we inform the police. Where it is unclear which Member State is concerned, we inform the authorities of the Netherlands or Europol.
We report child sexual abuse material to the Dutch hotline (Expertisebureau Online Kindermisbruik) and to the police in every case.
11. Repeated misuse
11.1 Repeated manifestly illegal content
If an account frequently provides manifestly illegal content, we suspend it for a reasonable period after a prior warning. If the conduct continues after the suspension, we may terminate the account. For child sexual abuse material and terrorist content we may terminate an account at once.
11.2 Manifestly unfounded notices and complaints
If a person or entity frequently submits notices or complaints that are manifestly unfounded, we may, after a prior warning, suspend the processing of their notices and complaints for a reasonable period.
11.3 How we decide
We decide case by case, taking into account the absolute number of manifestly illegal items or manifestly unfounded notices in a given period, their proportion of the total, their seriousness and consequences, and, where it can be identified, the intention of the person concerned.
These rules follow article 23 of the DSA. Article 23 applies to online platforms. To the extent the exemption for micro and small enterprises in article 19 applies to LeraLink, we apply these rules as our own policy rather than as a legal obligation.
12. Fundamental rights
LeraLink exists to publish knowledge. We apply our rules with due regard to the rights and legitimate interests of everyone involved, as article 14(4) of the DSA requires, and in particular to the rights in the Charter of Fundamental Rights of the European Union:
- Freedom of expression and information (art. 11). Lawful content is not removed because it is controversial, critical, offensive to some readers or politically unwelcome.
- Freedom of the arts and sciences, including academic freedom (art. 13). Research, scholarly debate and the discussion of difficult material are assessed in their academic context.
- Freedom and pluralism of the media. Journalistic work is assessed in its journalistic context, including reporting on illegal acts.
- Respect for private life and protection of personal data (arts. 7 and 8). We act on content that unlawfully exposes people.
- Protection of intellectual property (art. 17(2)).
- Non-discrimination (art. 21) and the rights of the child (art. 24).
When rights conflict, we choose the least restrictive measure that is effective, for example restricting visibility or limiting a measure to the Member States where content is illegal, rather than removal everywhere.
13. Transparency
To the extent the exemption in article 15(2) of the DSA applies, as LeraLink is operated by a micro enterprise, we are not obliged to publish the transparency reports described in article 15. For the same reason, to the extent article 19 applies, the additional obligations for online platforms in Section 3 of Chapter III of the DSA do not apply to us, including the submission of statements of reasons to the European Commission's transparency database.
We will reassess these points if LeraLink no longer qualifies as a micro or small enterprise.
14. Contact
| Purpose | Address |
|---|---|
| Notices of illegal content and breaches of our terms | legal@lera.link, subject line Content report (see Report Content) |
| Complaints about a moderation decision | legal@lera.link |
| Authorities, orders and the DSA single point of contact | legal@lera.link |
Changes to this policy are announced as described in the Change Notification Policy.