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Fictional product, illustrative draft. Not legal advice.

Shutterline Notice and Complaint Procedures

Draft for counsel review. Law as of 20 October 2026. This is not legal advice. This document sets out, step by step, how to report content, how to complain about a decision we made, and how a rights holder flags infringing content. It implements the policy stated in our [Content and Moderation Policy] and the process duties in our [Terms of Service].

1. How to report a photo, comment or message

  1. Tap or click "Report" on the photo, comment, or message you want to report. (For a direct message, the report control sits in the message thread, visible only to you as the recipient.)
  2. Choose the reason that best matches your concern: illegal content, infringes my copyright or trademark, harassment, impersonation, spam, or other (with a free-text field).
  3. Tell us, in your own words, why you believe the content is illegal or breaks our rules. Be as specific as you can; a report that only says "this is bad" without an explanation cannot be acted on as quickly as one that explains the problem.
  4. Confirm the exact location of the content (our form captures this automatically from the photo, comment or message you tapped "Report" on; you do not need to find a link yourself).
  5. Give your name and email address, so we can confirm we received your report and tell you our decision. (You do not need to give these if your report concerns child sexual abuse material; our form skips this step for that category.)
  6. Confirm, by ticking the box, that you believe in good faith that the information in your report is accurate and complete. We will not accept a report without this confirmation.
  7. Submit the report.

What happens next. If you gave us your email address, we confirm we received your report, without undue delay, by email. We review the report and tell you our decision, with information on how to challenge it if you disagree, also without undue delay. We will tell you if an automated tool, a person, or both were involved in reaching the decision.

A report that gives us all of the information in steps 3 to 6 above is treated as giving us actual knowledge of the content for the purposes of our own legal responsibility for it, so we prioritise a complete report over an incomplete one.

2. How you are told about a decision affecting your own content or account

If we restrict the visibility of, remove, or disable access to your content, or restrict, suspend or terminate your account, because of a report or our own review, and we have a way to reach you, we send you a statement that covers:

  • what we decided (for example: removed a photo, restricted a comment's visibility, suspended your account for 14 days);
  • why, including the facts we relied on and whether a report or our own review led to the decision;
  • whether an automated tool was involved;
  • the rule we applied (a specific law, or a specific section of our [Content and Moderation Policy]) and why your content or conduct did not meet it; and
  • how to challenge it: the internal complaint process below, the out-of-court settlement route (for EU users), and your right to go to court, which is never affected by anything in this document.

3. How to raise an internal complaint

If you disagree with a decision we made about your content or your account:

  1. Go to Settings → Account → Appeals, or reply directly to the decision notice we sent you.
  2. Select the decision you are appealing.
  3. Tell us why you believe the decision was wrong. You can attach evidence (for example, proof you own the rights to a photo that was removed for alleged infringement).
  4. Submit your appeal.

What happens next. A trained member of our team, not an automated tool alone, reviews your appeal. We handle every appeal in a timely, non-discriminatory, diligent, non-arbitrary way. Where your appeal shows we had it wrong, we reverse our decision without undue delay. We tell you our reasoned outcome, and, if you are in the EU, the out-of-court settlement route described below.

For EU users: this appeal channel stays open to you for at least six months from the date we told you about the decision you are appealing.

4. Out-of-court settlement (EU users)

If our internal appeal process (Section 3) does not resolve your complaint, you can bring it to any certified out-of-court dispute settlement body of your choice. [List or link to the certified bodies Lumenfolk works with, or state that any body certified under the Digital Services Act can be chosen.]

We engage with the body you choose in good faith. We will only refuse to take part where the same dispute, on the same grounds, has already been resolved through this process once before. Your right to go to court instead, or in addition, is not affected at any stage.

If the body decides in your favour, we pay all of its fees and reimburse your other reasonable expenses. If it decides against you, you owe nothing towards our own costs or fees, unless the body finds you acted manifestly in bad faith.

5. Rights holders: reporting infringement

Using the general report form

Use the steps in Section 1 above and select "Infringes my copyright or trademark" as the reason. This works for any intellectual-property claim, anywhere in the world, under our [Content and Moderation Policy].

If you are a copyright owner, or authorised to act for one, and want to use the formal US notice-and-takedown process, send a written notice to our designated agent containing:

  1. Your physical or electronic signature (or that of someone authorised to act for you).
  2. Identification of the copyrighted work you say is infringed (or a representative list, if more than one work on Shutterline is affected).
  3. Identification of the infringing material, with enough information for us to locate it on Shutterline (a direct link, or a description specific enough to find it).
  4. Your contact information: name, address, telephone number and email address.
  5. A statement that you have a good faith belief that the use is not authorised by the copyright owner, its agent, or the law.
  6. A statement, under penalty of perjury, that the information in your notice is accurate and that you are authorised to act on behalf of the copyright owner.

Send this to our designated agent at: [designated agent name, postal address, phone number and email address: also filed with the US Copyright Office].

What happens next. We review your notice against the six elements above. If it is complete, we act expeditiously to remove or disable access to the identified material. We notify the user who posted it and give them the chance to send a counter notice (below).

Counter notice (for a user whose content was removed)

If your content was removed because of a copyright notice and you believe this was a mistake or misidentification, you can send a counter notice to our designated agent containing:

  1. Your physical or electronic signature.
  2. Identification of the material removed and where it appeared before removal.
  3. A statement, under penalty of perjury, that you have a good faith belief the material was removed as a result of a mistake or misidentification.
  4. Your name, address and telephone number, and a statement that you consent to the jurisdiction of the federal court for your district (or, if outside the US, any district where Shutterline may be found), and that you will accept service of process from the person who filed the original notice or their agent.

What happens next. We notify you that we have received a valid counter notice (if you were the original notifier), and, unless you tell us within ten business days that you have filed a lawsuit asking a court to restrain the user from the infringing activity, we restore the material between ten and fourteen business days after we received the counter notice.

6. Reporting illegal content to an authority, or receiving an authority order

Where an authority order under the Digital Services Act requires us to act against content or provide information, we check it for the legal basis relied on, a statement of reasons, precise identification of the content, redress information, and, for an order to act against content, its territorial scope, before acting on it. We notify the affected user of the order and that same information no later than when we give it effect.