Fictional product, illustrative draft. Not legal advice.
Photo community with user content¶
The request¶
We are Lumenfolk Media GmbH, Spichernstrasse 12, 50672 Koeln, Germany, legal@lumenfolk.test, managing director
Theresa Brandt. We run Shutterline, a free online community for hobby photographers: people upload their own
photos, comment on other people's photos, and send each other direct messages. We do not charge users
anything; the business is funded entirely by advertising, both plain contextual ads next to the photo feed and
ads personalised to what a user has looked at and liked. About 2 million monthly active users in the EU,
almost all of them in Germany, France and Spain, and about 1.5 million monthly active users in the United
States. We have 120 employees and about EUR 20 million in annual turnover. Minimum age to create an account is
16, checked by self-declared birth date at signup. Photos, comments, direct messages and profile data are
stored on our own servers in the EU. We want the terms of service, the content and moderation policy covering
what happens when someone reports a photo or a comment as infringing or against the rules, the notice and
complaint flows a user or a rights holder can use, and a clear list of what our product (the upload flow, the
report button, the complaint and appeal screens, the ad labelling) actually has to implement. Our outside
counsel reviews everything before launch.
What the skill asked back¶
- Which EU member states beyond Germany, France and Spain, if any, Shutterline actually sells into or directs marketing to.
- Whether Shutterline's turnover or headcount has changed, and whether it qualifies as a micro or small enterprise under the EU recommendation that sets those categories.
- How personalised advertising is actually built: from on-platform activity only, or also from cross-site tracking, app SDK data, or bought third-party data.
- Whether Shutterline processes payment data, runs a mobile app with its own SDKs, or stores data outside the EU.
- Whether Shutterline has crossed the CCPA's own revenue or data-volume thresholds.
- What the actual age-verification mechanism is beyond self-declared birth date, and whether any feature makes the product attractive to, or predominantly used by, under-16s.
- Who the actual contact points are for DSA authorities and users, and whether there is a named data protection officer.
- Whether Shutterline wants a US arbitration and class-action-waiver clause.
The hand-over¶
| File | What it contains |
|---|---|
| reply.md | The questions above, and the list of files below, as the skill sent them back to the client. |
| terms-of-service.md | The main Shutterline Terms of Service: acceptance, content licence, acceptable use, moderation pointer, intellectual property, advertising, liability, governing law and dispute resolution, with EU, Germany and US modules throughout. |
| content-moderation-policy.md | What Shutterline does not allow, how a moderation decision is made, the DSA notice-and-action and trusted-flagger flows, the misuse-suspension policy, and the US Section 230 and repeat-infringer rules. |
| notice-and-complaint-procedures.md | The step-by-step flows a user or rights holder actually follows: reporting content, receiving a statement of reasons, raising an internal complaint, out-of-court settlement, and the DMCA notice and counter-notice process. |
| privacy-notice.md | The GDPR and CCPA-style privacy notice: what is collected, the legal basis for each purpose, data sharing, retention, EU rights, and the US state privacy layer. |
| cookie-notice.md | The cookie and tracking-technology notice: an EU opt-in consent model by category, plus a US opt-out note for cross-context behavioural advertising. |
| impressum.md | The German legal notice (Impressum) under the DDG, with a completeness check against the mandatory disclosure items. |
| annotations.md | The applicability table for every instrument considered, the clause-by-clause legal basis, and the checklist tables run against the drafts. |
| open-points.md | The facts the client has not yet confirmed, the national-law gaps, the rules not yet in force, and the decisions reserved for counsel. |
| implementation-requirements.md | The hand-over register to product and engineering: what the upload flow, report button, appeal screens and ad labelling must do, with the legal basis for each requirement. |
Corrections¶
None: the hand-over is shown as produced.
The drafts are for review by a qualified lawyer. Law as of 20 October 2026.