Trust & Safety and Compliance Policy
This Trust & Safety and Compliance Policy (“Policy”) describes how Marketspace Solutions OU, a company duly incorporated and existing under the laws of the Republic of Estonia, having its registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152 (“we”, “us”, “our”, “Publisher” or “Administrator”), keeps the Gem Space platform (the “Platform”) safe and lawful.
It explains our approach to the moderation of user-generated content, the mechanisms available for reporting illegal content and abuse, the way we handle illegal content, our cooperation with public authorities, and our compliance with the Digital Services Act and the Terrorist Content Online Regulation. This Policy forms part of, and should be read together with, our Terms of Use and our Privacy Policy. Capitalised terms not defined here have the meaning given to them in the Terms of Use.
1. Scope and Legal Framework
1.1. This Policy applies to all versions of the Platform, including the web version and the Android and iOS applications, and to all content and conduct of users on the Platform.
1.2. As a provider established in the Republic of Estonia, we provide our services within the European Union and we are subject to the supervision of the competent Estonian authorities, including the Estonian Digital Services Coordinator. Because we are established in the European Union, we are not required to designate a separate legal representative under Article 13 of the Digital Services Act.
In particular, we have designed this Policy with regard to the following legal framework:
– Regulation (EU) 2022/2065 (the Digital Services Act, or DSA);
– Regulation (EU) 2021/784 on addressing the dissemination of terrorist content online (the TCO Regulation);
– Regulation (EU) 2016/679 (the General Data Protection Regulation, or GDPR); and
– applicable national legislation of the Republic of Estonia.
1.3. For the purposes of the DSA, we act as a provider of hosting services and, where applicable, of an online platform. The specific obligations that apply to us depend on our classification and size under the DSA; where this Policy refers to mechanisms associated with online platforms, those mechanisms apply to the extent required by, and in accordance with, the DSA.
2. Prohibited and Illegal Content
2.1. “Illegal content” means any information or activity that, in itself or by reference to an activity, is not in compliance with European Union law or the law of any Member State, irrespective of the precise subject matter or nature of that law. Our full rules on acceptable use are set out in the Terms of Use.
Without limitation, the following content and conduct are strictly prohibited on the Platform:
– child sexual abuse material and any content or conduct that sexually exploits or endangers children;
– terrorist content, and content that incites, solicits, or glorifies terrorism or violent extremism;
– incitement to violence, hatred, or discrimination against persons or groups;
– content that facilitates serious crime, including fraud, trafficking in human beings, and the illegal sale of drugs, weapons, or other regulated goods;
– non-consensual intimate imagery, and harassment, threats, or stalking;
– infringement of intellectual property rights; and
– any other content or activity that is unlawful under applicable law.
3. Content Moderation
3.1. We are not subject to any general obligation to monitor the information that users transmit or store, or actively to seek facts or circumstances indicating illegal activity (Article 8 of the DSA). We may, however, carry out voluntary, own-initiative investigations and take measures to detect, identify, and address illegal content or breaches of our Terms of Use, and doing so does not, by itself, deprive us of the liability exemptions available to hosting service providers.
3.2. Moderation is carried out through a combination of user reporting (see Section 4) and, where proportionate, technical means and human review. The Platform is a communication service, and we apply moderation in a manner that respects the privacy and confidentiality of users' private communications. Our review focuses on content that is reported to us, content that is made available to the public (such as public channels and bots), and content that we are required to address under a valid order from a competent authority.
Where we identify illegal content or a breach of our rules, we may take one or more of the following actions, applied in a manner that is proportionate, diligent, objective, and non-arbitrary:
– removing or disabling access to the relevant content;
– restricting the visibility or distribution of the content;
– issuing a warning, or restricting, suspending, or terminating the account concerned; and
– restricting or suspending the provision of specific features to the user concerned.
4. Reporting Illegal Content and Abuse
4.1. Any individual or entity may notify us of content on the Platform that they consider to be illegal content, in accordance with Article 16 of the DSA. Reports can be submitted through the reporting tools available within the Platform or by writing to us at support@gemspace.com. The mechanism is easy to access and user-friendly and allows reports to be submitted by electronic means.
To allow us to assess a report, a notice should contain, so far as possible:
– a sufficiently substantiated explanation of why the content is considered illegal;
– a clear indication of the exact electronic location of the content, such as the relevant URL or identifier;
– the name and email address of the person or entity submitting the notice, except where the notice concerns content connected with certain offences against children; and
– a statement confirming the good-faith belief of the notifier that the information in the notice is accurate and complete.
4.2. Where a notice contains the contact details of the notifier, we will, without undue delay, confirm receipt of the notice and notify the notifier of our decision in respect of the content concerned, together with information on the redress available against that decision. A notice that enables us to identify the illegality of the content without a detailed legal examination may give rise to our actual knowledge or awareness of that content.
4.3. Users may also report other breaches of our Terms of Use, including spam, abuse, harassment, and impersonation, using the same channels.
5. Trusted Flaggers
5.1. In accordance with Article 22 of the DSA, notices submitted by entities that have been awarded the status of trusted flagger by a Digital Services Coordinator, acting within their designated area of expertise, are given priority and processed and decided upon without undue delay.
6. Decisions, Statement of Reasons, and Redress
6.1. Where we restrict the visibility of content, suspend or terminate the provision of our service, or suspend or terminate an account because of information provided by a user, we provide the affected user with a clear and specific statement of reasons, in accordance with Article 17 of the DSA. The statement of reasons sets out the action taken, the facts and circumstances relied upon, the legal or contractual ground for the action, and the redress mechanisms available.
6.2. To the extent applicable to us under the DSA, we operate an internal complaint-handling system that allows affected users to lodge complaints against our decisions, free of charge, for a period of at least six months following the decision (Article 20 of the DSA). Complaints are handled in a timely, non-discriminatory, diligent, and non-arbitrary manner.
6.3. Users also have the right to select a certified out-of-court dispute settlement body to resolve disputes relating to our decisions, in accordance with Article 21 of the DSA, and retain the right to bring proceedings before the competent courts.
7. Terrorist Content (TCO Regulation)
7.1. For the purposes of the TCO Regulation, we act as a hosting service provider, and we are committed to preventing the misuse of the Platform for the dissemination of terrorist content to the public.
7.2. Where we receive a removal order from a competent authority, we remove the terrorist content or disable access to it in all Member States as soon as possible and, in any event, within one hour of receipt of the removal order, in accordance with Article 3 of the TCO Regulation, subject to the safeguards and exceptions provided for in that Regulation.
7.3. Where a competent authority has determined that we are exposed to terrorist content, we put in place specific, targeted, and proportionate measures to protect the Platform against the dissemination of such content, in accordance with Article 5 of the TCO Regulation, having due regard to fundamental rights, in particular freedom of expression and information.
7.4. Terrorist content that has been removed or to which access has been disabled, together with related data, is preserved for six months, and for a longer period where required for ongoing administrative or judicial review proceedings, in accordance with Article 6 of the TCO Regulation, and is subject to appropriate technical and organisational safeguards.
7.5. We maintain a point of contact for the receipt of removal orders by electronic means, and we operate a complaint mechanism that allows content providers whose content has been removed under our own specific measures to request reinstatement, together with notice to the affected content provider, except where disclosure is restricted for reasons of public security.
7.6. We set out our policy on addressing terrorist content and, where we have taken or been required to take action in a given calendar year, we make publicly available an annual transparency report in accordance with Article 8 of the TCO Regulation.
8. Child Safety
8.1. We have a zero-tolerance approach to child sexual abuse material and to any content or conduct that sexually exploits or endangers children. Such material is strictly prohibited.
8.2. Where we become aware of such material, we remove it, terminate the accounts involved, preserve the relevant content and data to the extent permitted and required by law, and report it to the competent law-enforcement authorities and, where applicable, to the relevant reporting bodies.
8.3. Access to the Platform is subject to the minimum age requirements set out in the Terms of Use, and we reserve the right to verify the age of users and to take action against attempts to circumvent those requirements.
9. Cooperation with Public Authorities
9.1. Upon receipt of an order to act against one or more specific items of illegal content, issued by the relevant national judicial or administrative authority on the basis of applicable law, we act upon the order and inform the issuing authority of the effect given to it, in accordance with Article 9 of the DSA.
9.2. Upon receipt of an order to provide specific information about one or more individual users, issued by the relevant authority on the basis of applicable law, we provide that information in accordance with Article 10 of the DSA.
9.3. We may disclose user information, account data, or content to law-enforcement agencies, government authorities, and regulators where we receive a valid and lawful request, or where we believe in good faith that disclosure is necessary to prevent fraud, abuse, security threats, or illegal activity, or to protect the rights, safety, or property of our users or the public. We assess the validity and lawfulness of each request before responding.
9.4. Where we become aware of information giving 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 promptly inform the competent authorities and provide the relevant information available to us, in accordance with Article 18 of the DSA.
9.5. Where required and permitted by law, we make reasonable efforts to notify affected users before disclosing their information to authorities, unless we are legally prohibited from doing so or believe that notice would create a risk of harm, impede an investigation, or lead to the destruction of evidence.
9.6. Upon receipt of a valid legal request, we may preserve user data and account information for the period required by law, including after the deletion of an account.
10. Points of Contact
10.1. We maintain a single electronic point of contact enabling competent authorities to communicate with us directly in relation to the DSA (Article 11), and a point of contact enabling users to communicate with us by electronic means (Article 12). For the receipt of removal orders under the TCO Regulation, we maintain a dedicated point of contact. These points of contact can be reached at support@gemspace.com, and communications may be conducted in English.
11. Measures Against Misuse
11.1. In accordance with Article 23 of the DSA, and after issuing a prior warning, we may suspend, for a reasonable period, the accounts of users that frequently provide manifestly illegal content. We may likewise suspend the processing of notices and complaints from persons or entities that frequently submit notices or complaints that are manifestly unfounded.
12. Transparency Reporting
12.1. To the extent required of us under the DSA and the TCO Regulation, we publish periodic transparency reports describing, among other matters, the orders received from authorities, the notices received, the content-moderation actions taken, and the complaints handled. Our transparency reports are made available on our corporate website.
13. Governance and Review
13.1. Responsibility for trust, safety, and compliance matters is assigned within our organisation, supported by appropriate internal procedures and training. We review and update this Policy and our underlying procedures periodically, and in response to changes in our services, in the applicable legal framework, or in the risks we identify.
14. Contact and Updates
If you have questions about this Policy, or wish to report illegal content or abuse, you may contact us at:
Email: support@gemspace.com
Marketspace Solutions OU
Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152
Republic of Estonia
This Trust & Safety and Compliance Policy was last modified on 29.06.2026. We reserve the right to amend or update this Policy at any time by posting the revised version here.
It explains our approach to the moderation of user-generated content, the mechanisms available for reporting illegal content and abuse, the way we handle illegal content, our cooperation with public authorities, and our compliance with the Digital Services Act and the Terrorist Content Online Regulation. This Policy forms part of, and should be read together with, our Terms of Use and our Privacy Policy. Capitalised terms not defined here have the meaning given to them in the Terms of Use.
1. Scope and Legal Framework
1.1. This Policy applies to all versions of the Platform, including the web version and the Android and iOS applications, and to all content and conduct of users on the Platform.
1.2. As a provider established in the Republic of Estonia, we provide our services within the European Union and we are subject to the supervision of the competent Estonian authorities, including the Estonian Digital Services Coordinator. Because we are established in the European Union, we are not required to designate a separate legal representative under Article 13 of the Digital Services Act.
In particular, we have designed this Policy with regard to the following legal framework:
– Regulation (EU) 2022/2065 (the Digital Services Act, or DSA);
– Regulation (EU) 2021/784 on addressing the dissemination of terrorist content online (the TCO Regulation);
– Regulation (EU) 2016/679 (the General Data Protection Regulation, or GDPR); and
– applicable national legislation of the Republic of Estonia.
1.3. For the purposes of the DSA, we act as a provider of hosting services and, where applicable, of an online platform. The specific obligations that apply to us depend on our classification and size under the DSA; where this Policy refers to mechanisms associated with online platforms, those mechanisms apply to the extent required by, and in accordance with, the DSA.
2. Prohibited and Illegal Content
2.1. “Illegal content” means any information or activity that, in itself or by reference to an activity, is not in compliance with European Union law or the law of any Member State, irrespective of the precise subject matter or nature of that law. Our full rules on acceptable use are set out in the Terms of Use.
Without limitation, the following content and conduct are strictly prohibited on the Platform:
– child sexual abuse material and any content or conduct that sexually exploits or endangers children;
– terrorist content, and content that incites, solicits, or glorifies terrorism or violent extremism;
– incitement to violence, hatred, or discrimination against persons or groups;
– content that facilitates serious crime, including fraud, trafficking in human beings, and the illegal sale of drugs, weapons, or other regulated goods;
– non-consensual intimate imagery, and harassment, threats, or stalking;
– infringement of intellectual property rights; and
– any other content or activity that is unlawful under applicable law.
3. Content Moderation
3.1. We are not subject to any general obligation to monitor the information that users transmit or store, or actively to seek facts or circumstances indicating illegal activity (Article 8 of the DSA). We may, however, carry out voluntary, own-initiative investigations and take measures to detect, identify, and address illegal content or breaches of our Terms of Use, and doing so does not, by itself, deprive us of the liability exemptions available to hosting service providers.
3.2. Moderation is carried out through a combination of user reporting (see Section 4) and, where proportionate, technical means and human review. The Platform is a communication service, and we apply moderation in a manner that respects the privacy and confidentiality of users' private communications. Our review focuses on content that is reported to us, content that is made available to the public (such as public channels and bots), and content that we are required to address under a valid order from a competent authority.
Where we identify illegal content or a breach of our rules, we may take one or more of the following actions, applied in a manner that is proportionate, diligent, objective, and non-arbitrary:
– removing or disabling access to the relevant content;
– restricting the visibility or distribution of the content;
– issuing a warning, or restricting, suspending, or terminating the account concerned; and
– restricting or suspending the provision of specific features to the user concerned.
4. Reporting Illegal Content and Abuse
4.1. Any individual or entity may notify us of content on the Platform that they consider to be illegal content, in accordance with Article 16 of the DSA. Reports can be submitted through the reporting tools available within the Platform or by writing to us at support@gemspace.com. The mechanism is easy to access and user-friendly and allows reports to be submitted by electronic means.
To allow us to assess a report, a notice should contain, so far as possible:
– a sufficiently substantiated explanation of why the content is considered illegal;
– a clear indication of the exact electronic location of the content, such as the relevant URL or identifier;
– the name and email address of the person or entity submitting the notice, except where the notice concerns content connected with certain offences against children; and
– a statement confirming the good-faith belief of the notifier that the information in the notice is accurate and complete.
4.2. Where a notice contains the contact details of the notifier, we will, without undue delay, confirm receipt of the notice and notify the notifier of our decision in respect of the content concerned, together with information on the redress available against that decision. A notice that enables us to identify the illegality of the content without a detailed legal examination may give rise to our actual knowledge or awareness of that content.
4.3. Users may also report other breaches of our Terms of Use, including spam, abuse, harassment, and impersonation, using the same channels.
5. Trusted Flaggers
5.1. In accordance with Article 22 of the DSA, notices submitted by entities that have been awarded the status of trusted flagger by a Digital Services Coordinator, acting within their designated area of expertise, are given priority and processed and decided upon without undue delay.
6. Decisions, Statement of Reasons, and Redress
6.1. Where we restrict the visibility of content, suspend or terminate the provision of our service, or suspend or terminate an account because of information provided by a user, we provide the affected user with a clear and specific statement of reasons, in accordance with Article 17 of the DSA. The statement of reasons sets out the action taken, the facts and circumstances relied upon, the legal or contractual ground for the action, and the redress mechanisms available.
6.2. To the extent applicable to us under the DSA, we operate an internal complaint-handling system that allows affected users to lodge complaints against our decisions, free of charge, for a period of at least six months following the decision (Article 20 of the DSA). Complaints are handled in a timely, non-discriminatory, diligent, and non-arbitrary manner.
6.3. Users also have the right to select a certified out-of-court dispute settlement body to resolve disputes relating to our decisions, in accordance with Article 21 of the DSA, and retain the right to bring proceedings before the competent courts.
7. Terrorist Content (TCO Regulation)
7.1. For the purposes of the TCO Regulation, we act as a hosting service provider, and we are committed to preventing the misuse of the Platform for the dissemination of terrorist content to the public.
7.2. Where we receive a removal order from a competent authority, we remove the terrorist content or disable access to it in all Member States as soon as possible and, in any event, within one hour of receipt of the removal order, in accordance with Article 3 of the TCO Regulation, subject to the safeguards and exceptions provided for in that Regulation.
7.3. Where a competent authority has determined that we are exposed to terrorist content, we put in place specific, targeted, and proportionate measures to protect the Platform against the dissemination of such content, in accordance with Article 5 of the TCO Regulation, having due regard to fundamental rights, in particular freedom of expression and information.
7.4. Terrorist content that has been removed or to which access has been disabled, together with related data, is preserved for six months, and for a longer period where required for ongoing administrative or judicial review proceedings, in accordance with Article 6 of the TCO Regulation, and is subject to appropriate technical and organisational safeguards.
7.5. We maintain a point of contact for the receipt of removal orders by electronic means, and we operate a complaint mechanism that allows content providers whose content has been removed under our own specific measures to request reinstatement, together with notice to the affected content provider, except where disclosure is restricted for reasons of public security.
7.6. We set out our policy on addressing terrorist content and, where we have taken or been required to take action in a given calendar year, we make publicly available an annual transparency report in accordance with Article 8 of the TCO Regulation.
8. Child Safety
8.1. We have a zero-tolerance approach to child sexual abuse material and to any content or conduct that sexually exploits or endangers children. Such material is strictly prohibited.
8.2. Where we become aware of such material, we remove it, terminate the accounts involved, preserve the relevant content and data to the extent permitted and required by law, and report it to the competent law-enforcement authorities and, where applicable, to the relevant reporting bodies.
8.3. Access to the Platform is subject to the minimum age requirements set out in the Terms of Use, and we reserve the right to verify the age of users and to take action against attempts to circumvent those requirements.
9. Cooperation with Public Authorities
9.1. Upon receipt of an order to act against one or more specific items of illegal content, issued by the relevant national judicial or administrative authority on the basis of applicable law, we act upon the order and inform the issuing authority of the effect given to it, in accordance with Article 9 of the DSA.
9.2. Upon receipt of an order to provide specific information about one or more individual users, issued by the relevant authority on the basis of applicable law, we provide that information in accordance with Article 10 of the DSA.
9.3. We may disclose user information, account data, or content to law-enforcement agencies, government authorities, and regulators where we receive a valid and lawful request, or where we believe in good faith that disclosure is necessary to prevent fraud, abuse, security threats, or illegal activity, or to protect the rights, safety, or property of our users or the public. We assess the validity and lawfulness of each request before responding.
9.4. Where we become aware of information giving 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 promptly inform the competent authorities and provide the relevant information available to us, in accordance with Article 18 of the DSA.
9.5. Where required and permitted by law, we make reasonable efforts to notify affected users before disclosing their information to authorities, unless we are legally prohibited from doing so or believe that notice would create a risk of harm, impede an investigation, or lead to the destruction of evidence.
9.6. Upon receipt of a valid legal request, we may preserve user data and account information for the period required by law, including after the deletion of an account.
10. Points of Contact
10.1. We maintain a single electronic point of contact enabling competent authorities to communicate with us directly in relation to the DSA (Article 11), and a point of contact enabling users to communicate with us by electronic means (Article 12). For the receipt of removal orders under the TCO Regulation, we maintain a dedicated point of contact. These points of contact can be reached at support@gemspace.com, and communications may be conducted in English.
11. Measures Against Misuse
11.1. In accordance with Article 23 of the DSA, and after issuing a prior warning, we may suspend, for a reasonable period, the accounts of users that frequently provide manifestly illegal content. We may likewise suspend the processing of notices and complaints from persons or entities that frequently submit notices or complaints that are manifestly unfounded.
12. Transparency Reporting
12.1. To the extent required of us under the DSA and the TCO Regulation, we publish periodic transparency reports describing, among other matters, the orders received from authorities, the notices received, the content-moderation actions taken, and the complaints handled. Our transparency reports are made available on our corporate website.
13. Governance and Review
13.1. Responsibility for trust, safety, and compliance matters is assigned within our organisation, supported by appropriate internal procedures and training. We review and update this Policy and our underlying procedures periodically, and in response to changes in our services, in the applicable legal framework, or in the risks we identify.
14. Contact and Updates
If you have questions about this Policy, or wish to report illegal content or abuse, you may contact us at:
Email: support@gemspace.com
Marketspace Solutions OU
Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152
Republic of Estonia
This Trust & Safety and Compliance Policy was last modified on 29.06.2026. We reserve the right to amend or update this Policy at any time by posting the revised version here.