Content Moderation and Takedown Policy

This document is provided in English and Georgian. In case of discrepancy, the English version shall prevail.

Document: Content Moderation & Takedown Policy
Version: 1.1
Effective Date: 15 October 2026
Last Updated: 15 October 2026
Operated by: Nixyum LLC · Reg. No. 400458045
Address: Tbilisi, 13 Nikoloz Janashia Street, Georgia
Governing Law: Georgia

1. Introduction and Purpose

This Content Moderation & Takedown Policy ("Policy") sets out the legal framework governing Nixyum's authority and obligations with respect to User-generated Content on the Platform. It describes the grounds on which Content may be removed or restricted, the rights of Users in the moderation process, the procedure for intellectual property takedown notices and counter-notices, and Nixyum's approach to legal compliance requests.

This Policy is the substantive legal document. The internal procedures by which Nixyum applies it are not published. They cannot reduce anything this Policy promises, and if they ever differ from it, this Policy prevails. Everything that affects Users directly is set out in this Policy itself: what Nixyum may do, how Users are notified, how to appeal, and how long reviews take.

This Policy is incorporated by reference into the Terms of Service and forms part of the binding agreement between Nixyum and each User. Capitalised terms used in this Policy have the meanings assigned in the Master Definitions.

2. Scope

This Policy applies to:

All User-generated Content on the Platform, including posts, comments, direct messages, profile information, images, video, audio, links, and any other material a User creates, uploads, or transmits through the Platform.
Content posted as a Nex or as a Nyx.
All Users, regardless of account standing or of any commercial relationship with Nixyum.
Content in all languages.
External notices submitted by rights-holders, law enforcement agencies, and regulatory authorities requesting content removal or preservation.

3. Grounds for Content Removal or Restriction

Nixyum may remove, restrict, label, or otherwise act upon Content on any of the following grounds:

3.1 Violation of Community Guidelines

Content that violates the Community Guidelines is subject to removal or restriction. The Community Guidelines define the specific categories of prohibited Content, including but not limited to: hate speech; harassment; threats of violence; child sexual abuse material (CSAM); sexually explicit material; fraud and scams; malware; harmful misinformation; privacy violations; and platform integrity abuse. The Community Guidelines are incorporated by reference into this Policy and into the Terms of Service.

3.2 Violation of the Terms of Service

Content that constitutes a breach of the Terms of Service — including unauthorised commercial use, misuse of Nex and Nyx, and conduct that endangers the Platform's technical integrity — is subject to removal.

3.3 Unlawful Content Under Georgian Law

Content that is unlawful under applicable Georgian law is subject to immediate removal regardless of whether it constitutes a violation of the Community Guidelines. This includes content that constitutes a criminal offence, infringes Georgian intellectual property law, violates the Georgian Data Protection Law, or is otherwise prohibited by Georgian statute or regulation.

3.4 Intellectual Property Infringement

Content that infringes the copyright, trademark, or other intellectual property rights of a third party is subject to removal upon receipt of a valid takedown notice in accordance with Section 8 of this Policy, or at Nixyum's discretion upon becoming aware of the infringement.

3.5 Valid Legal Order or Law Enforcement Request

Content that is the subject of a valid court order, law enforcement request, or regulatory direction requiring removal, restriction, or preservation is subject to action in accordance with Section 10 of this Policy.

3.6 Nixyum's Discretionary Authority

In addition to the specific grounds above, Nixyum reserves the right to remove or restrict Content that Nixyum, in its reasonable discretion, determines to be: harmful to the safety or wellbeing of Users or third parties; damaging to the integrity of the Platform; inconsistent with the spirit of the Community Guidelines even if not captured by a specific rule; or likely to expose Nixyum to legal liability. Nixyum's exercise of this discretionary authority is subject to the principles of proportionality and consistency.

4. Range of Enforcement Actions

Where Content or conduct falls within the grounds set out in Section 3, Nixyum may take one or more of the following Enforcement Actions:

Content removal: the Content is removed, and other Users can no longer see it. Copies may be kept as evidence for the periods set out in the Data Retention Schedule. CSAM is handled as set out in Section 12.2.
Holding Content pending review: the Content is kept from other Users until a person has reviewed it. Its author can still see it.
Formal warning: a written warning that names the rule that was broken and what further breaches may lead to. It is recorded on the Account.
Restriction of a Nex or a Nyx: the restricted identity can still be used to read, but cannot post, comment or send messages, for a set period or until the restriction is lifted. The User's other identity is not affected.
Temporary Account suspension: the whole Account is suspended for a set period, during which the User cannot sign in.
Permanent Account termination: the Account is closed for good and its Content is removed. Hashed identifying data is kept to prevent re-registration, as set out in the Data Retention Schedule.
Referral to the authorities: CSAM is reported to NCMEC and, where required, to the competent authorities; other criminal conduct may be referred to Georgian law enforcement, as Georgian law requires or where Nixyum considers it necessary.

Enforcement Actions are applied in proportion to the severity of the violation, the User's history on the Platform, and the potential for harm. For a sufficiently serious violation, Nixyum may take any Enforcement Action, whether or not a lesser action was taken before.

5. Detection and Initiation of Review

Moderation review may be initiated by any of the following:

A Report submitted by a User through the in-app reporting function or by email to [email protected].
Automated systems using Nixyum's own Trust & Safety Models. They can keep Content from other Users until a person has reviewed it, but they never take an Enforcement Action against an Account (see Section 6.1).
Proactive review by a Moderator of publicly accessible Content on the Platform.
An intellectual property takedown notice submitted to [email protected].
A request under Section 9A to remove non-consensual intimate imagery.
A law enforcement request, court order, or regulatory direction.
An emergency notification from any person identifying a credible imminent threat to life or safety.

Reports are handled in order of severity. Reports of an imminent threat to life or safety, of CSAM and of terrorism are dealt with first: Nixyum aims to act on them within two (2) hours. Reports of severe harassment, hate speech, non-consensual intimate imagery and doxxing are reviewed within 24 hours, and requests under Section 9A lead to removal within 48 hours. All other reports are reviewed within five (5) business days. A Report may concern specific Content or a User's overall conduct. Reporting in bad faith, including false, malicious or coordinated reports, is itself a breach of the Community Guidelines.

6. Moderation Principles

6.1 Human Oversight

No Enforcement Action affecting a User's Account standing, including warnings, restrictions, suspensions and terminations, is taken solely by automated means: a Moderator decides. Automated tools help find Content that may break the rules, and may keep such Content from other Users until a person has reviewed it; its author can still see it. The sole exception is Content matching known CSAM, which is blocked automatically on upload and never published, on the basis of a legal obligation, as set out below.

Blocking Content that matches known CSAM is a decision based solely on automated processing with legal effect, within the meaning of the Georgian Data Protection Law. It is made under the legal-obligation exception on the following bases: (a) Nixyum's legal obligation under Georgian criminal law to prevent the dissemination of child sexual abuse material; (b) the substantial public interest in the protection of children from sexual exploitation; and (c) compliance with applicable CSAM-reporting law in respect of reports to NCMEC (see REPORT Act in the Master Definitions). Because blocked Content is never published, the uploader is not told the reason for the block. A User who believes that an upload was blocked in error may appeal under Section 11.2; the appeal is decided by a person, without viewing the material itself. Once a person has confirmed that Content is CSAM, the decision cannot be appealed.

Automated moderation uses Nixyum's own Trust & Safety Models, which run on servers in EU/EEA data centres provided by a processor under a written data processing agreement. No third-party AI service receives User Content.

6.2 Consistency and Impartiality

Moderation decisions are based on the Content and its context, applied consistently against the Community Guidelines and this Policy. Enforcement Actions are not applied differently based on the identity, nationality, religion, political views, or Account status of a User. Public figures and ordinary Users are subject to the same standards. Advertisers do not receive preferential treatment in moderation decisions.

6.3 Context Assessment

Context is a mandatory element of moderation review. Content that would constitute a violation in one context may be permissible in another. Moderators are required to consider: the purpose and framing of the Content; the platform and conversation context in which it appears; the intent reasonably discernible from the Content; and whether the Content falls within a recognised exception (journalistic, educational, counter-speech, artistic, or public interest). Where context materially affects the outcome, it will be documented in the moderation record.

6.4 Equal Treatment of Nex and Nyx

Responsibility for a violation attaches to the Account, whichever identity committed it: a violation committed as a Nyx has the same consequences as one committed as a Nex. Enforcement Actions may apply to the whole Account or, where proportionate, to one identity only. A Nyx gives no immunity from Enforcement Actions.

7. User Notification

Nixyum notifies the affected User of each Enforcement Action taken against their Content or Account, in the app. Where the action affects the whole Account, such as a suspension or a termination, Nixyum also notifies the User by email, because the User cannot sign in to read an in-app notice. A notice states: the action taken; the provision of the Community Guidelines, the Terms of Service or the law on which it rests; how long it lasts, where it is temporary; and whether and how it can be appealed, with the deadline.

Nixyum may withhold a notice where Georgian law requires or permits it, including where a law enforcement authority prohibits notification, or where a notice would compromise an active investigation. No notice is sent for Content blocked before it was ever published, or for routine automated spam filtering that does not affect an Account's standing. A failure to notify does not invalidate the Enforcement Action.

People who report. A User who submits a Report is told when the review is complete and whether action was taken. The identity of the User who made a Report is never disclosed to the User reported.

8. Intellectual Property Takedown Procedure

8.1 Basis

Nixyum respects the intellectual property rights of third parties and complies with its obligations under Georgian copyright law and applicable international intellectual property frameworks. Nixyum operates a notice-and-takedown procedure consistent with international best practice for user-generated content platforms. Where Nixyum acts in good faith in response to a valid and complete takedown notice, it is not liable to the User who posted the Content for the resulting removal.

8.2 How to Submit a Takedown Notice

Intellectual property infringement notices must be submitted by email to [email protected]. A valid notice must include all of the following elements:

Identification of the intellectual property right claimed to be infringed (e.g., specific copyright work, registered trademark, or other protected right) with sufficient detail to identify it.
Identification of the Content on the Platform claimed to be infringing, including the URL or other location information sufficient for Nixyum to locate the Content.
A statement that the submitting party has a good faith belief that use of the Content is not authorised by the intellectual property owner, its agent, or applicable law.
A statement, made under the submitting party's own responsibility and with awareness of the consequences of a false statement under Georgian law, that the information in the notice is accurate and that the submitting party is the rights-holder or is authorised to act on the rights-holder's behalf.
The full legal name, address, telephone number, and email address of the submitting party.
A physical or electronic signature of the submitting party.

Notices that are incomplete will not be processed. Nixyum will notify the submitting party if additional information is required.

8.3 Processing of Valid Notices

Upon receipt of a complete and valid takedown notice, Nixyum will:

Review the notice for completeness and apparent validity within five (5) business days.
Where the notice appears valid: remove or disable access to the identified Content promptly.
Notify the User who posted the Content of the removal and provide a summary of the grounds, unless notification is prohibited or would compromise an investigation.
Record the action in the moderation log.

Nixyum reserves the right to decline to act on a notice where the notice is facially invalid, frivolous, or appears to be submitted in bad faith. Submitting a false or knowingly inaccurate takedown notice may result in liability to the Content poster and to Nixyum for any resulting harm, and will result in the submitting party being barred from submitting further notices.

8.4 Repeat Infringer Policy

Nixyum maintains a repeat infringer policy. Users who have Content removed following multiple valid intellectual property takedown notices, or who are found to systematically post infringing Content, are subject to escalating Enforcement Actions up to and including permanent Account termination.

9. Counter-Notice Procedure

9.1 Right to Submit a Counter-Notice

A User whose Content has been removed pursuant to an intellectual property takedown notice may submit a counter-notice if they have a good faith belief that the Content was removed as a result of a mistake or misidentification of the Content as infringing.

9.2 How to Submit a Counter-Notice

Counter-notices must be submitted by email to [email protected] within fourteen (14) days of notification of the removal. A valid counter-notice must include:

Identification of the Content that was removed, with sufficient information to locate it.
The User's full legal name, address, telephone number, and email address.
A statement that the User has a good faith belief that the Content was removed as a result of a mistake or misidentification.
A statement that the User consents to the jurisdiction of the courts of Georgia for any dispute arising from the removal.
A statement, made under the User's own responsibility and with awareness of the consequences of a false statement under Georgian law, that the information in the counter-notice is accurate.
The User's physical or electronic signature.

9.3 Processing of Counter-Notices

Upon receipt of a valid counter-notice, Nixyum will:

Forward the counter-notice to the party who submitted the original takedown notice.
If the original complainant does not notify Nixyum of the commencement of legal proceedings within fourteen (14) days of receipt of the counter-notice, Nixyum may, at its discretion, restore the removed Content.
Notify the User of the outcome.

Restoration of Content is at Nixyum's discretion. Nixyum is not obligated to restore Content and will not do so where it independently determines the Content to be infringing or otherwise in violation of the Community Guidelines.

9A. Non-Consensual Intimate Imagery — Public Takedown Procedure

This Section establishes a dedicated, publicly accessible takedown procedure for non-consensual intimate imagery (NCII), including imagery generated, manipulated, or altered by computational means (Synthetic NCII or "deepfake NCII"). It operates in addition to, and independently of, the general reporting flow available to logged-in Users and the intellectual-property takedown procedure set out in Sections 8 and 9.

9A.1 Public Reporting Channel

Any person depicted in intimate imagery posted on the Platform without their consent — or an authorised representative acting on their behalf (including a parent or legal guardian where the depicted person is a minor) — may submit a takedown request through the public NCII reporting form available at https://support.nixyum.com/takedown. The form is reachable without a Nixyum Account and without registration. If the form is temporarily unavailable, reports may be submitted by email to [email protected] with the subject line "NCII TAKEDOWN".

9A.2 Required Information

A valid takedown request must include: (i) the URL or identifier of each item of Content to be removed; (ii) a statement, made in good faith, that the depicted person did not consent to the publication of the imagery; (iii) sufficient identifying information for Nixyum to contact the requester regarding the request; and (iv) a statement, made under the requester's own responsibility and with awareness of the consequences of a false statement under Georgian law, that the information in the request is accurate and that the requester is the depicted person or is authorised to act on their behalf. Nixyum may request additional verification where reasonably necessary.

9A.3 Removal Timeline

Upon receipt of a valid takedown request meeting the requirements of Section 9A.2, Nixyum will remove or disable access to the identified Content within forty-eight (48) hours of receipt. This timeline applies regardless of the requester's jurisdiction, reflecting Nixyum's voluntary alignment with the timelines and substantive standards of the TAKE IT DOWN Act (as defined in the Master Definitions) and equivalent obligations under applicable Georgian and international law. Where a request is materially incomplete, Nixyum will notify the requester promptly and the 48-hour clock will recommence upon receipt of the missing information.

9A.4 Reasonable-Effort Removal of Identical Re-Uploads

After Content is removed under this Section, Nixyum will make reasonable efforts to find and remove identical or substantially similar copies of it that are uploaded to the Platform later.

9A.5 Account Action

The Account responsible for the upload of Content removed under this Section will be subject to Enforcement Action under Section 4, up to and including immediate permanent termination. Where the conduct discloses a criminal offence under Georgian law, Nixyum will preserve evidence in accordance with Section 12 and refer the matter to Georgian law enforcement authorities.

9A.6 Counter-Notice Not Available

The counter-notice procedure in Section 9, which applies to intellectual property takedowns, does not apply to removals under this Section. The uploading User may appeal under Section 11.2, but the removed Content is not restored as a precautionary measure while the appeal is pending.

9A.7 Bad-Faith Reports

Submitting a takedown request under this Section that is materially false or made in bad faith may itself constitute a violation of Georgian law and of the Terms of Service. Where the requester is a Nixyum User, such conduct constitutes a separate Enforcement Action ground.

10. Law Enforcement and Legal Compliance

10.1 Responding to Legal Orders

Nixyum will comply with valid court orders, law enforcement requests, and regulatory directions issued under applicable Georgian law requiring the removal, restriction, preservation, or disclosure of Content or User data. Every such request is checked for authenticity before any action is taken.

Content removed pursuant to a legal order is not subject to Nixyum's standard appeal procedure. A User who disputes the underlying legal order must pursue their recourse through the appropriate Georgian judicial or administrative process.

10.2 User Notification of Legal Orders

Where a legal order does not prohibit notification, Nixyum will inform the affected User that their Content has been removed or restricted pursuant to a legal order, and will provide such information about the order as it is legally permitted to disclose. Nixyum will not disclose the existence of an order where disclosure is prohibited by the ordering authority.

10.3 Emergency Disclosures

Where Nixyum has a good faith belief that an imminent risk to the life or physical safety of any person exists, Nixyum may disclose relevant Content and User data to Georgian law enforcement authorities without awaiting a formal legal order. Such disclosures are documented in Nixyum's Legal Compliance Records in accordance with the Data Retention Schedule.

10.4 Orders from Other Countries

Nixyum does not restrict Content by country. Where Content is lawful in Georgia but subject to a valid legal order from another jurisdiction, Nixyum removes it only where a Georgian court or competent Georgian authority requires it, or where the Content independently violates the Community Guidelines.

10.5 Preservation Pending a Legal Request

Where Nixyum has reasonable grounds to believe that data relating to a User may be needed for a legal proceeding or a regulatory investigation, it may preserve that data beyond the periods in the Data Retention Schedule while a formal legal request is awaited. Preservation is not disclosure: preserved data is given to no one without a valid legal basis.

11. User Rights in the Moderation Process

11.1 Right to Notice

Users have the right to receive notification of Enforcement Actions taken against their Content or Account, subject to the exceptions in Section 7. Notification shall include the grounds for the action and information about the right of appeal.

11.2 Right of Appeal

Users may appeal an Enforcement Action within thirty (30) days of being notified of it. A later appeal is still considered where the User shows that they could not appeal in time for reasons beyond their control. Appeals can be made in the app (from the notice, or Settings → Help & Support) or by email to [email protected]. A suspended Nex or Nyx can still appeal in the app; an Account that is suspended or terminated cannot sign in, so its appeal is made by email. An appeal should say which action is appealed and when it was taken, why the User believes it was wrong or disproportionate, and any evidence or context the User wants considered.

The right of appeal does not apply to Enforcement Actions taken under a valid court order or law enforcement direction, to Content that a person has confirmed to be CSAM, or to terrorism-related content. An automated CSAM block can still be appealed, as Section 6.1 describes. Removals under Section 9A can be appealed, but the Content is not restored while the appeal is pending. Users are told when an action cannot be appealed.

Review. An appeal is decided by a Moderator who was not involved in the original decision. The reviewer re-examines the Content or conduct, the reasons recorded for the original action, and what the User has submitted. Nixyum aims to decide a standard appeal within seven (7) business days of receiving it, and a complex appeal, one that needs legal analysis or extensive evidence, within fifteen (15) business days. If more information is needed from the User, the period pauses until it arrives. Enforcement Actions stay in force while an appeal is pending.

Outcomes. If the appeal succeeds, Nixyum reverses the action, restores the Content where technically possible, removes the related violation record from the Account, and tells the User what it has done. If the action was justified but disproportionate, Nixyum may replace it with a lesser one, for example a temporary suspension instead of a termination, and tells the User. If the appeal fails, the action stands and the User is told why.

Finality. The appeal decision is final, unless the User later presents new material evidence that was not available at the time and could change the outcome. Abusing the appeal process, including repeated frivolous appeals, harassing Moderators, or giving false information, is itself a breach of the Terms of Service.

11.3 Right to Accurate Grounds

Nixyum shall specify the category of violation and the specific Community Guidelines provision, Terms of Service clause, or legal obligation that forms the basis for any Enforcement Action. Nixyum is not required to disclose the identity of a reporting User or internal investigative details.

11.4 Right to Contest

Users may contest the factual basis for an Enforcement Action through the appeal process. Nixyum will conduct a genuine re-examination of contested decisions by a Moderator who was not involved in the original decision. Appeals are not merely procedural reviews — they involve substantive reassessment of whether the Enforcement Action was correctly applied.

12. Preservation of Evidence

12.1 Non-CSAM Serious Violations

Content removed for serious violations — including credible threats of violence, terrorism-related material, NCII, fraud, and other categories defined in the Data Retention Schedule — may be retained internally as evidence for a period consistent with the Data Retention Schedule, even after removal from the Platform. Such retained Content is not accessible to other Users or disclosed to any party other than law enforcement, as permitted or required by Georgian law. Preserved evidence records are maintained with restricted access and used solely for legal compliance and moderation audit purposes.

12.2 Child Sexual Abuse Material (CSAM)

Where CSAM is identified, Nixyum blocks it and never publishes it, preserves it as sealed evidence to which access is strictly restricted, for the period set out in the Data Retention Schedule, and reports it to NCMEC and, where required, to the competent authorities. The User responsible faces immediate permanent Account termination, as Section D.2 of the Community Guidelines provides.

13. Limitation of Nixyum's Liability for Third-Party Content

Nixyum is an online platform that hosts User-generated Content. Nixyum does not create, endorse, or assume responsibility for User-generated Content. Content posted by Users expresses the views and intent of the User, not of Nixyum. Nixyum's status as a hosting service provider, and the conditions on which it may rely on hosting safe-harbor protection, are governed by applicable Georgian law on intermediary liability and information society services.

Nixyum is not liable for User-generated Content to the extent that:

Nixyum did not have actual knowledge of the unlawful or harmful nature of the Content at the relevant time; or
Upon obtaining such knowledge, Nixyum acted expeditiously to remove or disable access to the Content.

Where Nixyum takes action in good faith on the basis of a valid takedown notice or law enforcement request, it is not liable to the User who posted the Content for the resulting removal, provided the action was taken in accordance with this Policy.

Nixyum's liability for any failure to remove Content that has been the subject of a valid notice is limited to the extent provided by applicable Georgian law. Nothing in this section limits Nixyum's liability for its own actions or omissions, or for Content that Nixyum itself generates.

14. Transparency

Nixyum is committed to transparency in its moderation practices. Nixyum reserves the right to publish periodic transparency reports setting out aggregated, anonymised data on moderation activity, including:

Total Content removal volume by violation category.
Total Enforcement Actions by type.
Total valid intellectual property takedown notices received and processed.
Total law enforcement requests received and complied with.
Total appeals received and their outcomes.
Any other data Nixyum considers appropriate to publish.

Individual moderation records are not published. Transparency reports do not identify individual Users or individual Content items.

15. Changes to This Policy

Nixyum may update this Policy to reflect changes in law, Platform functionality, or operational practice. Material changes will be communicated to Users at least thirty (30) days before the change takes effect, via the Platform or by email, except where a shorter period is required by law or is necessary for reasons of security or regulatory compliance. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

16. Contact

Content Reports (Users): In the app · [email protected]
IP Takedown Notices: [email protected]
NCII Takedowns: [email protected] · https://support.nixyum.com/takedown
Appeals: In the app · [email protected]
Law Enforcement Requests: [email protected]
Support: [email protected]
Privacy & Data Protection: [email protected]
Security Disclosures: [email protected]
Data Controller: Nixyum LLC · Tbilisi, 13 Nikoloz Janashia Street, Georgia · Reg. No. 400458045
Supervisory Authority: State Audit Office of Georgia (SAO) · pdp.sao.ge