Acceptable Use Policy & Content Moderation Guidelines (AUP & UGC)

Version: 1.0
Effective Date: [INSERT DATE, E.G. OCTOBER 1, 2026]
Last Updated: [INSERT DATE]

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1. Purpose and Scope

1.1. This Acceptable Use Policy (hereinafter: "Policy" or "AUP") establishes standards for acceptable conduct and prohibited activities on the Struvo platform (including web and mobile applications), governs User-Generated Content (UGC), and sets forth procedures for reporting and moderating illegal content in full compliance with:

• Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital Services (Digital Services Act – DSA);
• Apple App Store Review Guidelines (Section 1.2 – User-Generated Content);
• Google Play Developer Program Policies.

1.2. All Clients, Authorized Users, and visitors are strictly required to adhere to this Policy.

1.3. Governing Language Clause: This Policy is drafted in the Polish language and translated into English. In the event of any discrepancies or conflicting interpretations, the Polish language version shall govern and prevail.

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2. Prohibited Content and Conduct

You agree not to upload, post, transmit, store, or distribute any content or engage in any conduct that:

2.1. Violates Laws and Safety Regulations:

• Is illegal under applicable national, European Union, or international law;
• Unlawfully promotes violence, terrorism or offences, or encourages conduct endangering life or health. Accurate documentation of defects, accidents or safety violations for a lawful purpose is not itself prohibited;
• Contains malicious code, viruses, spyware, trojans, or software vulnerabilities.

2.2. Infringes Intellectual Property and Privacy Rights:

• Infringes any patent, trademark, trade secret, copyright, or proprietary right of any third party (e.g., unauthorized blueprint uploads, proprietary engineering manuals);
• Violates the personal privacy, data protection, or publicity rights of individuals;
• Unlawfully processes identifiable persons’ images or protected information, or violates an applicable photography prohibition. Photographing property or a vehicle registration plate is not itself prohibited: purpose, a valid processing basis, access restrictions and others’ rights must be considered. Consent is not the only possible lawful basis.

2.3. Abuses Artificial Intelligence Features (AI Abuse):

• Submits adversarial prompts or inputs designed to circumvent safety filters, "jailbreak", or reverse-engineer AI models;
• Uploads synthetic or manipulated images intended to falsify construction milestone verifications or deceive building control authorities;
• Relies on AI outputs to deliberately bypass mandatory on-site physical engineering inspections.

2.4. Compromises System Integrity:

• Performs unauthorized vulnerability scanning, penetration testing, load stress attacks, or denial-of-service (DoS/DDoS) operations;
• Attempts to breach tenant database isolation (tennant_<uuid>) or access unauthorized tenant environments.

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3. DSA Single Point of Contact (Articles 11 & 12 DSA)

Pursuant to Articles 11 and 12 of the Digital Services Act, the Service Provider has designated a single electronic point of contact for communications with European Commission, Member State authorities, the European Board for Digital Services, and users:

• Designated Contact Email: support@struvo.pl (Subject line: "DSA / Content Notice")
• Supported Languages: Polish and English.

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4. Notice and Action Mechanism (Article 16 DSA)

Any individual or entity that becomes aware of illegal content or content violating this Policy hosted on Struvo may submit a formal notification.

4.1. Notice Requirements:
A notice must contain all of the following elements:

1. A sufficiently substantiated explanation of the reasons why the content is alleged to be illegal or non-compliant;
2. A clear indication of the exact electronic location of that information (e.g., URL, Project ID, Photo ID photoId, screenshot);
3. The name and email address of the individual or entity submitting the notice (except in notices concerning child sexual abuse material);
4. A statement confirming the bona fide belief of the notifier that the information and allegations contained in the notice are accurate and complete.

4.2. Notice Handling:

• The Service Provider promptly acknowledges receipt of the notice via email.
• The notice is assessed diligently, objectively, and in a non-discriminatory manner by qualified personnel.
• If content is found to be illegal, the Service Provider takes immediate corrective action (removal or disabling access).
• Both the notifier and the affected User receive formal notice of the decision and the grounds upon which it was based.

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The decision identifies the affected material, measure, scope and duration, relevant facts, legal basis or specific AUP provision, and available appeal. Any automation used for detection or the decision is disclosed in the reasons. Statutory exceptions apply, without unjustified disclosure of the notifier’s data.

5. Moderation Sanctions and Account Suspension

In the event of violations of this Policy, the Service Provider reserves the right to enforce the following proportional measures:

1. Formal warning to the User and Account Administrator;
2. Immediate removal or disabling of specific content (e.g., deleting infringing photos from Cloudflare R2 or purging log entries);
3. Temporary suspension of access to the Account or specific platform capabilities (e.g., revoking photo upload or AI analysis privileges);
4. Permanent termination of the Account and SaaS Agreement in cases of severe or repeated violations.

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6. Appeals Against Moderation Decisions

6.1. Affected Users and notifiers may appeal free of charge to support@struvo.pl within six months of notification, identifying the decision and reasons for challenge.

6.2. A suitably qualified human reviews the appeal within 14 business days and provides a reasoned decision. Errors are corrected without undue delay. Court remedies and other statutory rights remain available.

6.3. Struvo stores content at Clients’ request. Sharing documentation within a defined, closed project group does not itself establish the status of an online platform disseminating information to the public. Hosting duties and any additional platform duties depend on actual functions and the DSA, including Article 19. This appeal procedure is the Operator’s commitment even where Article 20 DSA does not apply.

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