Fictional product, illustrative draft. Not legal advice.

Shutterline Content and Moderation Policy¶

Draft for counsel review. Law as of 20 October 2026. This is not legal advice. Part of our [Terms of Service]; defined terms (Shutterline, Lumenfolk, user) carry the same meaning as in that document.

This policy states what you can and cannot post, comment or send on Shutterline, what happens when a photo, a comment or a direct message is reported as infringing a right or against our rules, and the decisions, statements of reasons, internal complaints and suspensions that follow. For the step-by-step process you actually use to submit a report or a complaint, see our [Notice and Complaint Procedures].

1. What Shutterline does not allow¶

You may not post, upload, send or otherwise make available on Shutterline:

content that is illegal in a place it is seen or shared, including content that infringes a third party's copyright, trademark or other intellectual-property right, or a third party's privacy or personality rights (for example, a photo of a recognisable person posted without a basis to do so);
content that is sexually exploitative of a minor, regardless of context;
content that harasses, threatens, or is intended to intimidate another user;
spam, or a comment or direct message sent in bulk or through an automated means not authorised by us;
content that impersonates another person or Lumenfolk itself; or
any other content or conduct our [Terms of Service], Section 6 (Acceptable use) describes as against our rules.

We apply and enforce this list diligently, objectively and proportionately, weighing the rights and legitimate interests of everyone affected, including your freedom of expression. We do not pre-screen content before it is posted, and nothing in this policy should be read as promising that we do.

2. How a decision is made, and who or what makes it¶

We use a combination of automated tools and human review to assess reported content and content we identify on our own initiative. An automated tool may flag or temporarily hide content pending human review; a final decision to remove content, restrict its visibility, or restrict, suspend or terminate an account is made, or confirmed, by a trained member of our Trust & Safety team, not solely by automated means, except for content an automated system detects and removes under a standard, narrow policy such as a cryptographic-hash match against known child sexual abuse material, which we remove immediately without discretion.

We do not promise to review every piece of content before or after it is posted; our moderation activity is a voluntary, good-faith exercise of discretion over content we become aware of through a report, our own review, or an automated signal.

3. What happens when a photo or comment is reported¶

Anyone, whether or not they have a Shutterline account, can report a photo or a comment they believe is illegal or breaches our rules, using the "Report" control shown next to the content. See [Notice and Complaint Procedures] for exactly what the report form asks for.

EU users¶

Our report form is easy to access, user-friendly, and usable only by electronic means. It captures: a substantiated explanation of why the content is said to be illegal; a clear indication of its exact location on Shutterline; the reporter's name and email address (except for the narrow child-sexual-abuse-material offence categories where this is not required); and a statement that the reporter believes in good faith that the information and allegations in the report are accurate and complete (Art. 16(1), (2) Regulation (EU) 2022/2065). Where a report gives us all four of these elements, it gives us actual knowledge of the content for liability purposes, and we route it to a timely, diligent decision rather than a generic queue (Art. 16(3) Regulation (EU) 2022/2065).

We confirm receipt of a report without undue delay where the reporter gave contact details, and tell the reporter what we decided, with redress information, also without undue delay, including whether automated means were used in the decision (Art. 16(4) to (6) Regulation (EU) 2022/2065).

Where the content affects another user (for example, a photo or comment that user posted), and we restrict its visibility, remove it, or restrict, suspend or terminate that user's account because of it, we give that affected user a statement of reasons from the moment the restriction takes effect, wherever we hold their contact details (Art. 17(1), (2) Regulation (EU) 2022/2065). The statement covers: what we decided, its scope and duration; the facts we relied on and whether they came from a report or our own review; whether we used automated means; the legal or contractual ground and why the content or conduct fails it; and the redress routes available, written clearly enough that the affected user can actually use them (Art. 17(3), (4) Regulation (EU) 2022/2065). This duty applies whether the restriction started from a report or from our own review, and applies to both the two carve-outs named in the Digital Services Act (deceptive high-volume commercial content, and an authority order) only to the extent those carve-outs genuinely apply.

United States: copyright-specific reports¶

Where a report concerns a photo or other content you believe infringes your copyright, see Section 8 of our [Terms of Service] for the notice-and-takedown process under the Digital Millennium Copyright Act, including the elements a valid notice must contain, our designated agent, and the counter-notice process available to the user who posted the content.

4. What happens when a direct message is reported¶

A direct message is private between its sender and recipient; we do not otherwise access its content. If a recipient reports a direct message as illegal or against our rules, we review the reported message and its surrounding context as described in the report, applying the same standards as for public content. The same notice, decision and redress mechanics in Section 3 (EU users) apply to a reported direct message as to a reported photo or comment, adapted to the fact that only the reported message, not the recipient's full inbox, is reviewed.

5. Rights holders: reporting infringing content¶

A rights holder who believes their copyright, trademark or other intellectual-property right is infringed by content on Shutterline can use the same report form as any other user (Section 3), or, for a US copyright claim specifically, the dedicated process in Section 8 of our [Terms of Service]. A trademark or other non-copyright rights claim is handled through the general report form and the process in Section 3.

EU users: trusted flaggers¶

Where a report comes from an entity holding Digital-Services-Coordinator-awarded trusted-flagger status, acting within its designated area of expertise, we give it priority, undue-delay processing automatically (Art. 22(1) Regulation (EU) 2022/2065). Where we have information that a trusted flagger has submitted a significant number of insufficiently precise, inaccurate or inadequately substantiated reports, we report that, with explanation and supporting documents, to the awarding Digital Services Coordinator, rather than unilaterally de-prioritising the flagger ourselves (Art. 22(6), (7) Regulation (EU) 2022/2065).

6. Internal complaints¶

If you disagree with a decision we made about your content or your account, you can raise an internal complaint; see [Notice and Complaint Procedures] for how.

EU users¶

Our internal complaint system stays open to you for at least six months from the notification of the decision you are complaining about, lets you lodge a complaint electronically and free of charge against a decision on a report, a content removal or visibility restriction, a service suspension or termination, an account suspension or termination, or a monetisation restriction (Art. 20(1), (2) Regulation (EU) 2022/2065). We decide every complaint in a timely, non-discriminatory, diligent, non-arbitrary way, reversing our original decision without undue delay where your complaint shows we had it wrong (Art. 20(4) Regulation (EU) 2022/2065). We tell you the reasoned outcome and the out-of-court settlement route available to you without undue delay (Art. 20(5) Regulation (EU) 2022/2065). Every complaint is decided under the supervision of appropriately qualified staff, never solely by automated means (Art. 20(6) Regulation (EU) 2022/2065).

7. Out-of-court settlement¶

EU users¶

If our internal complaint process does not resolve your complaint, you can bring it to any certified out-of-court dispute settlement body; see [Notice and Complaint Procedures] for how to do this. We engage with the body you choose in good faith, and refuse only where the same dispute, on the same grounds, has already been resolved this way. Going to court stays open to you at every stage of this process (Art. 21(1), (2) Regulation (EU) 2022/2065). If the body decides in your favour, we pay all its fees and your other reasonable expenses; if it decides against you, you owe nothing for our costs unless you clearly acted in bad faith (Art. 21(5) Regulation (EU) 2022/2065).

8. Misuse suspension policy¶

Where you, or an entity submitting reports or complaints, do this so often, and so far out of proportion to genuine reports or complaints, that it becomes clearly abusive, we warn you first and then suspend, for a period that fits the pattern, our handling of what you send us or your access to Shutterline. We base every suspension of this kind on a case-by-case assessment that weighs:

the absolute number of manifestly illegal items you posted, or manifestly unfounded reports or complaints you submitted, in a given period;
their proportion against the total content you posted, or reports or complaints you submitted, in that period;
the gravity of the misuse, including the nature and consequences of any illegal content involved; and
your apparent intention, where this can be identified.

Worked examples (updated as our practice changes, so this list stays current rather than generic):

Posting the same photo that was already removed for infringing a third party's copyright three or more times within 30 days results in a warning, then, on a further repeat, a 30-day suspension of your upload ability.
Submitting five or more reports found to be manifestly unfounded within a 14-day period results in a warning, then a 14-day suspension of your ability to submit further reports.
Sending direct messages that repeatedly breach the commercial-messaging restriction in our [Terms of Service], Section 6, after a first warning, results in a 7-day suspension of direct-messaging access, extending to an account-wide suspension on a further repeat.

(Art. 23(1) to (4) Regulation (EU) 2022/2065.)

9. Advertising on reported content¶

Where we restrict or remove content following a report, we also review whether that content was being shown with advertising and adjust accordingly; our advertising-labelling rules are in [Terms of Service], Section 10.

10. United States: Section 230 and repeat-infringer policy¶

We are not treated as the publisher or speaker of information a user or another information content provider supplies, and reviewing, filtering, labelling, restricting or removing it does not change that (47 U.S.C. § 230(c)(1)). This statement covers only content we did not ourselves create or develop (47 U.S.C. § 230(f)(3)). We do not promise full or guaranteed review of user content.

We terminate, in appropriate circumstances, the account of a user who is a repeat infringer of copyright, as a condition of the safe harbors we rely on under US copyright law (17 U.S.C. § 512(i)(1), (2)). A user whose account is terminated for repeat infringement is told the reason and can respond through our internal complaint process described in Section 6 before termination takes final effect, except where immediate termination is required to prevent ongoing infringement.

Nothing in this policy limits the enforcement of federal criminal law, including the obscenity and child-exploitation statutes; nothing here expands or limits intellectual-property law; and nothing here limits the Electronic Communications Privacy Act of 1986 or a similar state law (47 U.S.C. § 230(e)(1), (2), (4)). Neither the publisher/speaker immunity above nor the good-faith moderation immunity is a defense to a civil sex-trafficking claim tied to a violation of 18 U.S.C. § 1591, or to a matching state criminal prosecution (47 U.S.C. § 230(e)(5)(A) to (C)).