Inhouds- en moderatiebeleid
Versie 1.0
Dit is versie 1.0. De ingangsdatum is nog niet vastgesteld. Dit is de huidige versie.
Het document “Content and Moderation Policy” wordt in het Engels weergegeven. De Engelse tekst is de bindende versie. Bulgaarse vertaling
This Content and Moderation Policy is drawn up in English, and the English text is the only authentic version. A Bulgarian translation is provided for convenience; in the event of any discrepancy, the English text prevails. Neither that translation nor any other, including an automatic translation by your browser, has legal effect of its own. This does not derogate from any mandatory rule of law on the language in which information must be provided to you.
Ostany
Version: 1.0
Effective date: [date]
This Policy implements the requirements of Regulation (EU) 2022/2065 (Digital Services Act, "DSA"), in particular Articles 11 and 12 (points of contact), Article 14 (transparency of terms and conditions and of content moderation), Article 16 (notice and action mechanism), Article 17 (statement of reasons), Article 18 (notification of suspicions of criminal offences) and Article 24(3) (data on active recipients).
The Platform is a microenterprise within the meaning of Commission Recommendation 2003/361/EC and, pursuant to Articles 19 and 29 of the DSA, is exempt from the whole of Section 3 of Chapter III (Articles 20 to 28) and from Section 4 of Chapter III (Articles 30 to 32) thereof, as well as from the annual transparency report under Article 15(2). It nevertheless applies voluntarily the internal complaint-handling system under Section 7, the measures against misuse under Section 9 and the traceability of Business Hosts under Section 10. The scope of each exemption is stated in the relevant Section.
It forms an integral part of the Guest Terms and of the Host Terms.
1. Points of contact
| Purpose | Address |
| Single point of contact for authorities (Article 11 DSA) | [dsa-authorities@domain] |
| Point of contact for recipients of the service (Article 12 DSA) | [dsa@domain] |
| Notices of illegal content (Article 16 DSA) | Form at [link]; fallback: [notice@domain] |
| Complaints against measures (Section 7) | Form at [link] |
Languages of communication: Bulgarian, English and Greek.
Digital Services Coordinator for the Republic of Bulgaria: the Communications Regulation Commission (CRC), the Digital Services Coordinator for Bulgaria (www.crc.bg).
Digital Services Coordinator for the Hellenic Republic: Εθνική Επιτροπή Τηλεπικοινωνιών και Ταχυδρομείων (Ε.Ε.Τ.Τ., the Hellenic Telecommunications and Post Commission, the Digital Services Coordinator for Greece) (www.eett.gr), designated by Greek Law 5099/2024.
2. What content is prohibited
2.1. Illegal content
Content which is illegal under the law of the European Union or of a Member State is prohibited, including:
content constituting a criminal offence under the Bulgarian Criminal Code (Nakazatelen kodeks), including incitement to violence or hatred, terrorism, extortion, fraud, drug trafficking, human trafficking, prostitution;
child sexual abuse material;
content infringing intellectual property rights: photographs, texts, trade marks;
content infringing the personal data rights of third parties;
defamation and insult;
the offering of a Property which lacks the required registration or categorisation: for the Republic of Bulgaria, Article 113(3) of the Bulgarian Tourism Act (Zakon za turizma); for the Hellenic Republic, the absence of a valid Α.Μ.Α. (Αριθμός Μητρώου Ακινήτου / Arithmos Mitroou Akinitou, the Greek property registry number) in the Μητρώο Ακινήτων Βραχυχρόνιας Διαμονής (Mitroo Akiniton Vrachychronias Diamonis, the Greek Short-Term Rental Property Registry) or of a valid ΜΗ.Τ.Ε. (Μητρώο Τουριστικών Επιχειρήσεων / Mitroo Touristikon Epicheiriseon, the Greek Register of Tourism Enterprises) number under Article 111 of Greek Law 4446/2016;
misleading commercial practices under the Bulgarian Consumer Protection Act (Zakon za zashtita na potrebitelite), and correspondingly under Greek Law 2251/1994, and under Directive 2005/29/EC.
2.2. Content incompatible with the terms and conditions
Content which, without necessarily being illegal, is also prohibited where it:
is inaccurate, incomplete or misleading in respect of the Property: photographs of a different property, edited photographs creating a false impression, false description of the location or of the amenities;
is discriminatory on the basis of race, ethnicity, national origin, religion, sex, gender identity, sexual orientation, disability or age;
is insulting, vulgar, threatening or harassing;
contains personal data of third parties without a legal basis, including full names, addresses, telephone numbers and images of identifiable persons without their consent;
constitutes spam, advertising of third-party services or redirection outside the Platform;
is a review in breach of the rules under Section 3;
contains malicious code or links to malicious resources;
constitutes a duplicate Listing for the same property.
3. Rules on reviews
(1) A review may be left only by a person who: has a Booking confirmed through the Platform; and whose stay has actually commenced.
(2) Reviews are two-sided. They are published simultaneously, once both parties have submitted them or upon expiry of the 14-day period.
(3) The Platform does not verify the factual accuracy of the statements made in a review. A review expresses the personal opinion of its author. The Platform verifies only whether the conditions under paragraph 1 are met and whether the content does not infringe this Policy.
(4) The following are prohibited:
offering, requesting or providing a benefit in exchange for a review or for its removal;
publishing a review for one's own property or for a property of a related party;
publishing a review by a person who has not been a guest;
threatening or coercing with a view to influencing a review;
distorting reviews or publishing them selectively on the part of the Platform.
(5) The Platform does not remove a review merely because it is negative. Removal takes place only on the grounds under Section 2 or in the event of a breach of paragraph 4.
(6) If a review is removed, the affected party receives a statement of reasons under Section 6 and may lodge a complaint against it under Section 7.
(7) Automated messages published by the Platform on a Listing where the Host has cancelled without valid cause (Article 33(3), item 3 of the Host Terms) are not reviews within the meaning of this Section and are not subject to removal under the procedure laid down in paragraphs 5 and 6.
4. How we moderate
(1) No general monitoring obligation. The Platform does not systematically monitor all content and does not actively seek facts indicating illegal activity (Article 8 DSA).
(2) The Platform carries out voluntary own-initiative investigations and this does not deprive it of the protection under Articles 4–6 DSA (Article 7 DSA).
(3) We use a combination of automated means and human means:
| Method | Where it applies |
| Automated verification upon publication | Format and validity of the registration number; detection of duplicate listings; detection of telephone numbers, addresses and external links in the text; comparison of photographs against databases of known stolen images; language filters |
| Automated detection of behavioural patterns | Suspicious booking patterns, coordinated posting of reviews, multiple accounts |
| Human review | Every notice under Section 5; every complaint under Section 7; every measure leading to the suspension or termination of an account; every case flagged by an automated system as requiring assessment |
(4) A measure leading to the suspension or termination of an account is not imposed definitively solely by automated means without the possibility of human review at the request of the affected person.
(5) Where automated means have been used in the detection or in the taking of the decision, this is expressly stated in the statement of reasons under Section 6.
5. Notices of illegal content
(1) Any natural or legal person may notify the Platform of content which it considers to be illegal, by means of the form at [link].
(2) The notice should contain:
a sufficiently substantiated explanation of the reasons why the content is illegal;
the exact electronic location (URL) of the content and, where necessary, additional information enabling it to be identified;
the name and electronic mail address of the notifier, except where the notice concerns offences against the person or the sexual exploitation of children, in which case the notice may be submitted anonymously;
a statement confirming the notifier's bona fide belief that the information contained in the notice is accurate and complete.
(3) A notice which contains all the elements under paragraph 2 is deemed to give rise to actual knowledge within the meaning of Article 6 DSA.
(4) The Platform:
confirms receipt without undue delay where an electronic mail address is provided;
processes the notice in a timely, diligent, objective and non-arbitrary manner;
notifies the notifier of its decision and of the redress possibilities available;
states whether automated means were used in the processing.
(5) Trusted flaggers. As a microenterprise, the Platform is exempt from the obligation under Article 22 DSA. The Platform processes every notice diligently irrespective of its notifier and, at its own discretion, gives priority to notices submitted by trusted flaggers awarded that status by a Digital Services Coordinator.
(6) Notification of authorities. If the Platform becomes aware of any 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, it shall immediately inform the competent authorities (Article 18 DSA).
6. Measures and statement of reasons
6.1. Possible measures
| Measure | When |
| Removal of, or restriction of the visibility of, specific content | Breach under Section 2 by the specific content |
| Deactivation of a Listing | Breach affecting the entire Listing (missing registration number, misleading description) |
| Restriction of access to particular functionalities | Repeated breaches; suspicion of misuse |
| Suspension of an account | Material breach; safety risk |
| Suspension of payments | Suspicion of fraud; failure to comply with DAC7 or KYC obligations |
| Cancellation of Bookings | Where their performance would create a risk |
| Termination of the contract | Material or repeated breach |
| Withdrawal of a special status | Systematic non-compliance with the standards |
6.2. Principles governing the choice of measure
(1) The measure is applied diligently, objectively and proportionately, with due regard to the fundamental rights and legitimate interests of all parties involved, including the freedom of expression (Article 14(4) DSA).
(2) The least intrusive sufficient measure is applied. Termination is imposed only in the event of a material or repeated breach.
(3) In the case of non-material breaches, the affected person is notified in advance and is given a reasonable period to remedy the breach, except where such notification would: obstruct the detection or prevention of fraud or of another illegal activity; harm the legitimate interests of third parties; or be contrary to the law.
6.3. Statement of reasons (Article 17 DSA)
For every measure, the affected person receives a clear and specific decision containing:
the type of measure imposed and its territorial and temporal scope;
the facts and circumstances which led to the decision, including whether the decision was taken on the basis of a notice under Section 5 or on the Platform's own initiative;
whether automated means were used in the detection and in the taking of the decision;
where the content is considered to be illegal, the legal ground and an explanation of why the content is illegal on that ground;
where the content is incompatible with the terms and conditions, the specific contractual clause and an explanation of why the content is incompatible with it;
information on the redress possibilities available: the internal complaint-handling system under Section 7, the other remedies under Section 8 and judicial redress.
7. Internal complaint-handling system (voluntary, modelled on Article 20 DSA)
(1) The Platform operates an internal complaint-handling system voluntarily. As a microenterprise within the meaning of Commission Recommendation 2003/361/EC, it is exempt from the obligation under Article 20 of the DSA pursuant to Article 19 thereof. This does not diminish your rights under this Section: the commitments made here are binding on the Platform.
(2) The Platform operates a free of charge electronic complaint-handling system, accessible at [link].
(3) The following are entitled to lodge a complaint:
persons in respect of whom a measure under Section 6 has been imposed;
notifiers who submitted a notice under Section 5 which was rejected in whole or in part;
persons affected by a decision under Article 27, Article 33 or Article 34 of the Guest Terms (Booking Issue and Damage Report), in so far as such a decision constitutes a measure in respect of them.
(4) Period for lodging a complaint: six (6) months, from the communication of the measure or from the communication of the rejection.
(5) Complaints are handled in a timely, non-discriminatory, diligent and non-arbitrary manner. The Platform issues a reasoned decision within 14 days.
(6) A decision on a complaint is not taken solely by automated means. It is reviewed by a member of staff with the necessary qualifications who was not involved in taking the initial decision.
(7) Where a complaint is well-founded, the Platform reverses the measure without undue delay and, to the extent possible, restores the previous position.
8. Other remedies
(1) As a microenterprise, the Platform is exempt from the obligations under Article 21 of the DSA and does not undertake to engage in proceedings before a certified out-of-court dispute settlement body under that Article.
(2) If you are not satisfied with the decision under Section 7, the following remain available to you:
Judicial redress: your right to bring proceedings before the competent court is entirely unaffected and does not depend on the exhaustion of the internal procedure;
the Commission for Consumer Protection and the competent general conciliation commission attached to it, for disputes with consumers, under the conditions set out in Article 53 of the Guest Terms;
the Digital Services Coordinator (the Communications Regulation Commission for the Republic of Bulgaria and Ε.Ε.Τ.Τ. for the Hellenic Republic);
the Commission for Personal Data Protection, and correspondingly the Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (the Greek Data Protection Authority), for matters relating to the processing of personal data.
(3) If the Platform ceases to meet the criteria for a microenterprise, Article 21 of the DSA becomes applicable upon expiry of the twelve-month period under Article 19(2) thereof, and this Section will be amended accordingly.
9. Measures against misuse (voluntary, modelled on Article 23 DSA)
(1) The Platform applies the measures set out in this Section voluntarily; as a microenterprise it is exempt from the obligation under Article 23 of the DSA pursuant to Article 19 thereof.
(2) The Platform suspends, for a reasonable period of time, the provision of its services to a recipient of the service who frequently provides manifestly illegal content, after having issued a prior warning.
(3) The Platform suspends, for a reasonable period of time, the processing of notices and complaints submitted by a person who frequently submits manifestly unfounded notices or complaints, after having issued a prior warning.
(4) The assessment takes into account:
the number of items of manifestly illegal content, or of manifestly unfounded notices or complaints, submitted within a given period of time;
their relative proportion in relation to the total number of items of content or of submissions of that person;
the gravity of the misuse and of the harm caused;
the intention of the person, in so far as it can be established.
(5) The duration of the suspension is proportionate and is communicated to the person together with the reasons for it.
10. Traceability of Business Hosts
As a microenterprise, the Platform is exempt from Articles 30 to 32 of the DSA pursuant to Article 29 thereof. This Section nevertheless applies, because the collection and verification of the same data are required under Regulation (EU) 2024/1028, under Article 113 of the Bulgarian Tourism Act (Zakon za turizma, "TA") and under Directive (EU) 2021/514 (DAC7).
(1) Before allowing a Listing by a Business Host to be published, the Platform obtains and verifies the data listed in Article 30 of the DSA: name, address, telephone number, electronic mail address, identification document, payment account, trade register and registration number.
(2) Verification is carried out by consulting official online databases of the Union or of the relevant Member State (for the Republic of Bulgaria, the Commercial Register and the National Tourist Register; for the Hellenic Republic, the Μητρώο Ακινήτων Βραχυχρόνιας Διαμονής and the Μητρώο Τουριστικών Επιχειρήσεων (ΜΗ.Τ.Ε.), together with verification of the ΑΦΜ (A.F.M., the Greek tax identification number); and for other Member States, the corresponding national registers) and, where necessary, by requesting supporting documents.
(3) Where the information is found to be inaccurate or incomplete, the Platform requests its correction and suspends the offering until the correction is made.
(4) The information is retained for six months after the end of the contractual relationship.
(5) The contact details of the Business Host are made available to Guests before the conclusion of the contract.
11. Transparency
(1) The Platform provides the competent authorities, upon their request, with information on the average monthly active recipients of the service in the Union (Article 24(3) DSA).
(2) As a microenterprise, the Platform is exempt from the obligation to publish an annual transparency report under Article 15(2) of the DSA. The Platform maintains the necessary internal records so that it is able to produce such a report should it cease to meet the criteria for a microenterprise.
12. Amendments
This Policy is amended in accordance with the procedure laid down for the amendment of the Guest Terms and the Host Terms, with notice given at least 30 days before the entry into force of the amendment. Archive: [link].