Digital Services Act at LeraLink
How LeraLink meets the obligations of the Digital Services Act as a hosting service, and which obligations do not apply to it.
Last updated: 13 November 2026
Scope of this page
This page explains how SSStudio, trading as LeraLink ("we"), applies Regulation (EU) 2022/2065, the Digital Services Act (DSA). It is written for customers, for people who want to report content, and for authorities.
It summarises. The rules that bind users are in the Terms of Service, the Acceptable Use Policy and the Content Moderation Policy. How to report content is on Report Content.
What kind of service LeraLink is
LeraLink stores works and other information provided by its customers and their members, at their request, and makes much of it available to the public on installations and on the Hub. That makes LeraLink a hosting service within the meaning of art. 3(g)(iii) DSA.
Where an installation or the Hub disseminates information to the public at the request of the people who provide it, that part of the service may also qualify as an online platform (art. 3(i)). The additional obligations for online platforms are discussed below under "Obligations that do not apply".
LeraLink is not a very large online platform or a very large online search engine. It has not been designated as such and is far below the threshold of 45 million average monthly active recipients in the EU.
We are established in the Netherlands, so we do not need a legal representative in the EU (art. 13).
Obligations we meet
| Obligation | Article | How LeraLink meets it |
|---|---|---|
| Single point of contact for authorities | Art. 11 | legal@lera.link, in English and Dutch |
| Single point of contact for recipients of the service | Art. 12 | legal@lera.link, for DSA matters and for reports of illegal content, in English and Dutch. Report Content explains how to send a report. Messages are read by a person, not only by automated tools |
| Information in terms and conditions | Art. 14 | The Terms of Service, Acceptable Use Policy and Content Moderation Policy describe what is not allowed, how content is moderated, the measures that can be taken, whether automated tools are used, and how a decision can be questioned |
| Notice and action mechanism | Art. 16 | Report Content: a notice by email to legal@lera.link |
| Statement of reasons | Art. 17 | Given to the person affected when we restrict content or an account |
| Notification of suspected criminal offences | Art. 18 | Reported to the competent authorities when required |
| Orders to act against illegal content | Art. 9 | Handled through legal@lera.link |
| Orders to provide information | Art. 10 | Handled through legal@lera.link |
Points of contact (arts. 11 and 12)
- Authorities, the European Commission and the European Board for Digital Services: legal@lera.link.
- Recipients of the service and anyone else: legal@lera.link, also for reports of illegal content, as described on Report Content.
- Languages: English and Dutch. Support can also be given in Persian, but DSA communications are handled in English or Dutch.
These contacts are also listed in Company Information.
Terms and conditions (art. 14)
Our Terms of Service, Acceptable Use Policy and Content Moderation Policy are public, in plain language, and published as web pages that can be read by machines. They describe the restrictions we impose on content, the measures we can take (for example removing a work, restricting its visibility, or suspending an account), whether automated means are used in moderation, and how to ask for a decision to be reconsidered. We apply them in a diligent, objective and proportionate way, with regard for the rights and legitimate interests of everyone involved, including freedom of expression and of the press (art. 14(4)). We inform users of significant changes to the terms (art. 14(2)), as described in the Change Notification Policy.
Notice and action (art. 16)
Anyone can tell us about content they believe is illegal by email to legal@lera.link, with the subject line "Content report", as described on Report Content. No account is needed. A notice works best when it contains:
- an explanation of why the content is believed to be illegal;
- the exact address (URL) of the content;
- the name and email address of the person reporting, except for reports of child sexual abuse material;
- a statement that the report is made in good faith and is accurate and complete to the best of the reporter's knowledge.
We confirm receipt when the reporter has given contact details. We assess each notice in a timely, diligent, non-arbitrary and objective way, and tell the reporter what we decided and how they can seek redress. Notices are assessed by a person; we say so when automated means are used in processing or deciding on a notice.
A notice that meets these elements can give us actual knowledge of the content for the purposes of our liability as a hosting service (arts. 6 and 16(3)).
Statement of reasons (art. 17)
When we remove content, disable access to it, restrict its visibility, or suspend or end an account because content is illegal or breaks our terms, we tell the person affected, unless we do not have their contact details. The statement says:
- what we did, and for which content and period;
- the facts and circumstances relied on, including whether a notice was involved;
- whether automated means were used;
- the legal ground, where the content is considered illegal, or the rule in our terms, where it breaks them;
- how the decision can be challenged: by asking us to reconsider, through out-of-court dispute settlement where available, or before a court.
No statement of reasons is given where we act on an order from an authority under art. 9 (art. 17(5)). Personal data of the reporter is not disclosed unless that is necessary and lawful.
Notification of suspected criminal offences (art. 18)
When 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 has taken place, is taking place or is likely to take place, we inform the law enforcement or judicial authorities of the member state concerned without delay. In the Netherlands, these are the police and the Public Prosecution Service (Openbaar Ministerie). Where the member state cannot be identified, we inform the authorities of the Netherlands or Europol.
Orders from authorities (arts. 9 and 10)
Orders to act against illegal content and orders to provide information about specific users are received at legal@lera.link. We check that an order meets the conditions in art. 9(2) or 10(2), inform the issuing authority without undue delay of the effect given to it, and inform the person concerned as art. 9(5) and 10(5) require, unless the order says otherwise. Where an order concerns an installation's content, we may inform the installation customer, unless the order forbids it.
Obligations that do not apply
SSStudio is a micro enterprise within the meaning of Commission Recommendation 2003/361/EC. The DSA exempts micro and small enterprises from several obligations. To the extent these exemptions apply to LeraLink:
| Obligation | Article | Why it does not apply |
|---|---|---|
| Annual transparency reports on content moderation | Art. 15(1) | Art. 15(2) exempts micro and small enterprises that are not very large online platforms |
| Obligations for online platforms in Section 3 (internal complaint-handling system, out-of-court dispute settlement duties, trusted flaggers, measures against misuse, online interface design, advertising transparency, recommender systems, protection of minors, publishing user numbers, submitting statements of reasons to the Commission's database) | Arts. 20–28 | Art. 19(1) exempts micro and small enterprises, except for art. 24(3) |
| Obligations for online marketplaces | Arts. 29–32 | LeraLink is not an online marketplace; micro and small enterprises are also exempt (art. 29) |
| Obligations for very large online platforms | Arts. 33–43 | LeraLink is not a very large online platform |
Art. 24(3) still applies: on request of the Digital Services Coordinator or the Commission, we provide information on the average monthly active recipients of the service.
We still apply several of these practices voluntarily. A person affected by a moderation decision can ask us to reconsider it, as described in the Content Moderation Policy, and the Acceptable Use Policy allows us to suspend accounts that repeatedly misuse the service.
If SSStudio ceases to qualify as a micro or small enterprise, the exemption continues for 12 months (art. 19(1)), after which we will apply the full set of online platform obligations.
Installation owners who moderate their own communities
Installation customers run their own sites. Many let members comment, annotate, review or contribute, and moderate those contributions themselves.
- Our responsibility. We remain responsible as a hosting service for all information stored on the platform. A notice about content on any installation can be sent to us as described on Report Content.
- The customer's responsibility. A customer decides on content in its own installation under its own rules, within our Terms of Service and Acceptable Use Policy. A customer that opens its installation to the public may itself have duties under the DSA towards its own users. The customer is responsible for meeting them, and for its own house rules.
- How we work together. Where a notice concerns an installation, we may pass it to the installation's owner to handle under their rules. Where content is manifestly illegal, where an order requires it, or where the owner does not act, we act ourselves. The Content Moderation Policy describes this division.
Supervision
In the Netherlands, the Autoriteit Consument en Markt (ACM) is the Digital Services Coordinator and supervises most of the DSA, under the Dutch DSA Implementation Act (Uitvoeringswet digitaledienstenverordening), in force since February 2025. The Autoriteit Persoonsgegevens supervises certain provisions that concern personal data.
Anyone who believes we infringe the DSA may lodge a complaint with the Digital Services Coordinator of the member state where they are located or established; in the Netherlands, that is the ACM (art. 53).
Contact
DSA point of contact: legal@lera.link. Reports of illegal content: legal@lera.link, as described on Report Content.
Sources
- Regulation (EU) 2022/2065 (Digital Services Act): eur-lex.europa.eu
- Commission Recommendation 2003/361/EC concerning the definition of micro, small and medium-sized enterprises: eur-lex.europa.eu
- Uitvoeringswet digitaledienstenverordening (Stb. 2025, 21), in force February 2025: njb.nl
- Autoriteit Consument en Markt: acm.nl