GetClinic DSA / Content Moderation & Illegal Content Reporting Policy

1. Purpose and Scope

This Policy explains how GetClinic receives reports of illegal content, moderates user- and Clinic-provided information, communicates moderation decisions, and provides review or redress mechanisms. It applies to content and activity made available through GetClinic websites, mobile applications, patient and Clinic portals, reviews, profiles, listings, messages, uploads, marketplace tools and related services to the extent relevant to the particular feature.

The general moderation standards in this Policy may be applied globally. DSA-specific rights and procedures apply to recipients of the service in the European Union where the DSA applies to the relevant GetClinic service and activity.

This Policy should be read together with the GetClinic Terms of Service, Review Policy, Privacy Policy and other applicable marketplace policies. It does not replace a Clinic’s own medical, professional or regulatory obligations.

2. GetClinic’s Role and DSA Status

GetClinic operates a technology marketplace connecting Patients with independent Clinics. Some GetClinic functions may qualify as intermediary, hosting or online-platform services under the DSA because GetClinic may store information supplied by users or Clinics and, for certain features such as profiles or reviews, make that information available to others.

The DSA applies different duties depending on the nature and size of the service. Certain additional online-platform obligations are excluded for providers that qualify as micro or small enterprises unless an exception applies. GetClinic will assess its status and apply the obligations that legally apply to it. Where this Policy voluntarily provides a safeguard beyond a current statutory minimum, that does not constitute an admission that every DSA provision applies to every GetClinic feature.

3. What We Moderate

Content moderation means actions intended to detect, identify or address illegal content or information that violates GetClinic’s terms or policies. Depending on the feature, GetClinic may moderate:

• Clinic profiles, descriptions, credentials, accreditations, prices, Treatment claims and promotional materials;
• Patient and Clinic reviews, responses, ratings and public comments;
• usernames, profile images and other account information;
• marketplace messages or uploaded materials where review is permitted and reasonably necessary for safety, fraud prevention, legal compliance or enforcement;
• advertising, sponsored content or promotional claims;

• fraudulent, abusive, manipulative or security-related activity; and
• other information supplied through GetClinic that may be illegal, unsafe or inconsistent with our published rules.

Private health information is handled under GetClinic’s privacy and health-data documents. Content moderation does not give GetClinic a general right to inspect private medical information for unrelated purposes.

4. Illegal Content

For DSA purposes, “illegal content” generally means information that, in itself or in relation to an activity such as the sale of products or provision of services, does not comply with applicable EU law or the law of an EU Member State that is consistent with EU law.

Examples may include, depending on the applicable law and facts:

• fraud, scams, impersonation or deceptive commercial practices;
• unlawful or materially misleading healthcare advertising or claims;
• unlawful offers of healthcare services or use of falsified professional credentials;
• counterfeit or unlawfully marketed products;
• child sexual abuse material or other unlawful sexual-exploitation content;
• terrorist content or unlawful promotion of terrorism;
• unlawful threats, harassment or non-consensual intimate imagery;
• privacy or data-protection violations;

• intellectual-property infringement; or
• other content or activity prohibited by applicable law.

Content may violate GetClinic policy without being illegal. Conversely, a disagreement, unfavorable review, medical complaint or criticism is not illegal merely because another user or Clinic objects to it.

5. How to Report Illegal Content

Any individual or entity may notify GetClinic about a specific item of information they believe is illegal.

You may report content by:

• using the Report, Flag or similar function displayed next to content, a profile, review, listing or other item, where available; or
• emailing [email protected] if an in-product reporting mechanism is unavailable or unsuitable.

For general support issues, use [email protected]. For privacy-rights requests, use [email protected]. For medical emergencies, contact local emergency services; do not rely on the illegal-content reporting channel for emergency medical assistance.

6. What an Illegal-Content Notice Should Include

To allow GetClinic to make an informed decision, a report should be sufficiently precise and adequately substantiated. Please provide, where available:

• an explanation of why you believe the content is illegal;
• the exact URL, screen, profile, review, message identifier, listing identifier or other precise electronic location of the content;
• the country or legal jurisdiction relevant to the report, if known;
• supporting evidence or context reasonably necessary to understand the report;

• your name and email address, except where applicable law permits or requires a notice to be submitted without those details; and
• a good-faith statement that you believe the information and allegations in your notice are accurate and complete.

You do not need to be a lawyer or identify the exact legal provision. However, broad allegations such as “this Clinic is illegal” without identifying the content and explaining the issue may not provide enough information for GetClinic to act.

Do not send unnecessary medical records, identification documents or other sensitive personal information with a report. Include sensitive information only when it is genuinely necessary to explain the alleged illegality.

7. What Happens After You Submit a Notice

Where you provide contact information, GetClinic will send confirmation that your notice has been received. GetClinic will then assess the notice in a timely, diligent and objective manner.

Our review may include:

• confirming the reported content and its location;
• reviewing the information supplied by the reporter;
• checking applicable GetClinic terms and policies;
• requesting clarification or additional evidence where reasonably necessary;
• reviewing relevant law or seeking specialist advice where appropriate;
• considering the rights and legitimate interests of affected users, including freedom of expression and information;

• checking whether immediate action is required for safety, fraud, security or legal compliance; and
• documenting the decision and the basis for it.

A report does not automatically result in removal. GetClinic may conclude that the content is lawful, that the notice is insufficient, that a less restrictive measure is appropriate, or that another process is better suited to the issue.

Where contact information is available, GetClinic will notify the reporter of the decision without undue delay and explain available redress options.

8. Moderation Actions GetClinic May Take

Depending on the seriousness, legal basis, context and proportionality of the issue, GetClinic may take one or more of the following actions:

• take no action;
• request correction, clarification, substantiation or additional disclosure;
• apply a warning or informational label;
• reduce visibility or ranking;
• restrict discovery, recommendation or promotion;
• remove or disable access to particular content;
• restrict messaging, review, listing, booking or other functionality;
• suspend or terminate an account;
• suspend or remove a Clinic listing;
• preserve relevant information where lawfully required;

• refer or report a matter to a competent authority where required or permitted by law; or
• take other proportionate measures permitted by our terms and applicable law.

GetClinic will not remove a lawful negative review solely because a Clinic objects to its sentiment or rating. Review authenticity, privacy, relevance, manipulation and other review-specific rules are addressed in the Review Policy.

9. GetClinic-Initiated Moderation

GetClinic may identify potentially illegal, fraudulent, unsafe or policy-violating content without receiving an external report. This may occur through user complaints, internal controls, fraud or security signals, quality checks, automated detection tools or human review.

GetClinic does not undertake a general obligation to monitor all information transmitted or stored through the service. We may, however, carry out proportionate voluntary investigations or checks consistent with applicable law.

10. Automated Tools and Human Review

GetClinic may use automated technical signals or tools, human review, or a combination of both. Automated tools may assist with matters such as spam, duplicate content, fraudulent behavior, account abuse, security threats, review manipulation, prohibited content or misleading marketplace activity.

An automated flag does not necessarily result in an adverse decision. Human review may be used where appropriate or legally required. Immediate automated restrictions may be used where reasonably necessary to address urgent security, fraud, sanctions, legal or safety risks.

Where required by law, a statement of reasons will identify whether automated means materially contributed to the decision.

11. Statements of Reasons

Where the DSA requires GetClinic to provide a statement of reasons for a moderation decision affecting content supplied by a recipient of the service, the statement will be clear, specific and reasonably understandable. Depending on the decision, it may include:

• the restriction imposed, such as removal, disabling, visibility restriction, account restriction or other action;
• the territorial scope of a restriction where relevant;
• the principal facts and circumstances relied on, including whether the decision followed a notice or GetClinic’s own review;
• whether automated means were materially used;
• the legal basis where the decision concerns illegal content;

• the relevant GetClinic contractual or policy basis where the decision concerns a terms violation; and
• available internal or external redress options.

GetClinic may limit information where disclosure is prohibited by law, would compromise security, fraud prevention, another person’s rights, an investigation, or another legally protected interest.

12. Internal Review and Appeals

If you believe GetClinic made an incorrect content-moderation decision, you may request internal review by emailing [email protected] and identifying the relevant content, account and decision. This review route is free of charge.

GetClinic will arrange for the request to be reviewed by a qualified human. Review requests will be handled in a timely, diligent, non-discriminatory and non-arbitrary manner and will not be decided solely through automated means. GetClinic will communicate the outcome using the contact information you provide.

Where Article 20 of the DSA applies to GetClinic, GetClinic will provide any additional complaint-handling functionality, submission period, accessibility features and procedural safeguards required by that Article. Where Article 20 does not apply because of a lawful size-based or other exemption, the internal review process described above may still be available under GetClinic’s Terms and procedures. The availability of voluntary review does not alter the legal classification of GetClinic or create rights beyond those expressly stated.

13. External Redress in the European Union

Where applicable under the DSA, an eligible recipient may have additional redress options, including certified out-of-court dispute settlement and judicial remedies. Recipients may also have the right to lodge a complaint with the Digital Services Coordinator of the relevant EU Member State under applicable DSA procedures.

Use of GetClinic’s internal process does not prevent a person from contacting a competent regulator, law-enforcement authority or court where they are legally entitled to do so.

14. Reports From Trusted Flaggers and Authorities

Where the DSA trusted-flagger regime applies to GetClinic, notices submitted by an entity formally awarded trusted-flagger status by an EU Digital Services Coordinator will receive the priority and processing required by applicable law.

GetClinic will process legally valid orders or requests from competent authorities according to the DSA and other applicable law. Government or law-enforcement communications intended for GetClinic’s DSA authority point of contact should be sent to [email protected] unless another official channel has been communicated.

15. High-Risk or Urgent Content

Certain reports may require accelerated handling because they concern an immediate safety, security or legal risk. Examples may include credible threats of serious violence, child sexual exploitation, terrorist content, active fraud or compromised accounts.

GetClinic may preserve information, restrict access, escalate internally or make reports to appropriate authorities where required or permitted by law. GetClinic is not an emergency response service. If there is an immediate threat to life or safety, contact local emergency or law-enforcement services directly.

16. Healthcare and Clinic-Specific Reports

GetClinic may moderate marketplace information involving healthcare providers, including unlawful or misleading Treatment claims, falsified credentials, impersonation, deceptive pricing information, unlawful advertising, fabricated reviews or other marketplace misconduct.

A report that a Patient is dissatisfied with a Treatment outcome does not by itself establish illegal content. Clinical negligence, malpractice, medical licensing and professional-conduct matters may need to be raised with the Clinic, insurer, professional regulator, health authority, court or other competent body. GetClinic may still take marketplace action when the underlying content or conduct violates GetClinic rules or applicable law.

17. Misuse of Reporting and Appeal Systems

Reports and appeals must be made in good faith. GetClinic may take proportionate action against manifestly abusive use of reporting or complaint mechanisms, including repeated submission of clearly unfounded notices, fraudulent evidence, harassment, attempts to suppress lawful criticism, or coordinated manipulation.

Any restriction for abusive use will be applied consistently with applicable law and the GetClinic Terms. Good-faith reporting does not violate this Policy merely because GetClinic ultimately disagrees with the reporter.

18. Reporter Identity and Privacy

GetClinic processes information submitted through illegal-content reports for purposes such as evaluating the notice, communicating with the reporter, enforcing marketplace rules, protecting rights and safety, maintaining records, preventing abuse and complying with law. Processing is governed by the applicable GetClinic Privacy Policy.

GetClinic will not routinely disclose a reporter’s identity to the person whose content was reported. We may disclose information where necessary to identify or explain the alleged illegality, protect legal rights, comply with law, respond to lawful process, or where the reporter has authorized disclosure.

Reports may contain sensitive information. Report only the minimum information reasonably necessary for GetClinic to understand and investigate the issue.

19. Transparency Reporting

Where Article 15 of the DSA or another transparency-reporting obligation applies to GetClinic, GetClinic will publish the required content-moderation transparency report in the required format and on the applicable schedule. DSA rules provide an exemption from Article 15 reporting for qualifying micro and small enterprises that are not designated very large online platforms.

GetClinic may maintain internal moderation metrics even where a public reporting exemption applies. If GetClinic’s legal status changes so that additional transparency obligations become applicable, GetClinic will update its processes accordingly.

20. DSA Points of Contact

GetClinic’s public DSA contact information is:

Communications to the DSA point of contact may be made in English. GetClinic will maintain a recipient contact method that allows direct and rapid electronic communication and does not rely solely on automated tools.

21. EU Legal Representative

GetClinic offers intermediary services in the European Union without an establishment in the Union, so Article 13 of the DSA requires it to designate an EU legal representative. GetClinic has designated a representative in an EU Member State where it offers services, notified the appropriate Digital Services Coordinator, and makes the representative’s required identifying and contact information publicly available below.

GetClinic has designated Prighter GmbH, Schellinggasse 3, 1010 Vienna, Austria as its EU legal representative under Article 13 of the DSA. The representative may be addressed in English and can be held liable for non-compliance with obligations under the DSA, which does not affect the liability of GetClinic itself. Requests to the representative may also be sent to [email protected].

GetClinic, Inc. has designated Prighter GmbH as its legal representative according to Article 13 of the Digital Services Act (DSA). Prighter GmbH serves as the addressee for competent authorities in the Member States, for the European Commission and for the European Board for Digital Services on all matters related to the DSA. To contact Prighter GmbH, please visit https://app.prighter.com/portal/getclinic, which carries the contact details.

22. Changes to This Policy

GetClinic may update this Policy to reflect changes in law, regulatory guidance, moderation systems, product functionality or marketplace risks. We will update the Effective Date and version when changes are made. Where applicable law requires notice of a significant change to content-moderation terms, GetClinic will provide that notice.

23. Contact and Reporting Summary

Illegal content or DSA report: [email protected]

General platform support: [email protected]

Privacy request: [email protected]

Legal notice: [email protected]

For medical questions or medical emergencies, contact the selected Clinic or appropriate local emergency services, not the DSA reporting channel.

Legal Basis Note

This Policy is designed to support compliance, where applicable, with Regulation (EU) 2022/2065 on a Single Market for Digital Services (Digital Services Act), including the DSA provisions concerning points of contact, terms and conditions, notice-and-action mechanisms, statements of reasons, complaint handling and transparency. Applicable obligations depend on GetClinic’s role, service functionality, establishment and enterprise size.