This Moderation policy (the Policy) explains how ESMIRA LTD reviews and acts on Cyprus4People when it considers that the Community guidelines, the Terms of Service, or the law have been broken.

It does not restate everything that is forbidden: that lives in the Community guidelines. This document is the procedure: reports, criteria, measures, notices, and internal review.

It does not replace the Terms of Service or the Privacy Policy. If there is a conflict about contractual rights, obligations, or personal data, the Terms and the Privacy Policy prevail, in that order. This Policy and the Community guidelines are read together: on the same facts, this Policy governs how staff act, and the Guidelines govern what is allowed.

The version that counts is the one marked current in the Legal Hub. By using Cyprus4People you also accept this Policy.

1. Who runs the service

Cyprus4People is operated by ESMIRA LTD, a Cyprus company (HE431241), of Lambrou Katsoni, Flora Court, Block A, Office 204, 2nd Floor, 8011 Paphos, Cyprus. Contact: mail@esmiraweb.com · +357 94 090 540. Brand site: https://cyprus4people.com.

Staff act for ESMIRA. Moderation decisions are platform decisions, not a civil or criminal judgment between private parties.

2. Definitions

Unless the context requires otherwise, the definitions in the Community guidelines apply (platform, member, visitor, card, content, Space, staff).

In this Policy, in addition:

• Report: an Abuse Report ticket or another communication asking staff to look at content, an account, or conduct.
• Measure: any step staff take (hiding, removing, limiting, suspending, closing, refusing a card, and the like).
• Guidelines: the current Community guidelines in the Legal Hub.

3. Principles

ESMIRA applies these principles.

No general prior monitoring. ESMIRA is not obliged to review all content in advance. It may act on a report, on staff initiative, at the request of an authority, or when a fact comes to light in another lawful way (for example a related ticket, a claim on a card, an order).

Good faith and proportion. Staff assess in good faith. A measure should match the seriousness, the reasonably foreseeable harm, any repetition, and the context. Not every breach leads to account closure.

The same framework, not an automatic identical outcome. Similar cases are judged against the same criteria. Two facts that are not the same (tone, addressee, account history, urgency) may have different outcomes without that being arbitrary.

Safety first where it matters. Minors, imminent violence, trafficking, fraud in progress, malware: staff may act without prior notice and, where the law requires it, report to the authorities.

No crowd justice. Moderation is not a public vote or a review pile-on. Using reports or the feed to punish an opponent breaks the Guidelines.

Useful transparency, not total disclosure. ESMIRA may tell the member concerned what measure was taken. It is not required to reveal the reporter’s identity, internal methods, or details that would put others or the service at risk.

4. What can be moderated

This Policy applies to:

1. public and restricted content (cards, comments, reviews, messages, Spaces, files, links, metadata);
2. accounts, identity, card claims, automation;
3. Spaces and the people who administer them;
4. to a limited extent, off-platform conduct closely tied to the service, as already set out in the Guidelines (threats that started from a contact here, evasion of a measure, replacement accounts).

A commercial disagreement, an honest but uncomfortable review, or a heated debate is not, in itself, a reason to take content down. It becomes one if it breaks the Guidelines or the law.

5. How cases reach staff

Staff may look at a case when:

• a member or a rights holder opens an Abuse Report ticket;
• another support channel (for example Account Issue) reveals a conduct problem, and staff reclassify it;
• staff notice the fact in the course of operating the service;
• an authority or a lawful order requires it;
• a payments partner, host, or other provider flags a concrete risk (fraud, abuse, security).

Cyprus4People does not promise automated detection at global-social scale. If filters or automated signals are used later, they remain a support tool: the decision that matters for the user is staff’s, except for technical urgency (for example blocking malware).

6. How to report

6.1 Channel

For breaches of the Guidelines or content you believe is illegal: an Abuse Report ticket.

For your own personal data: Data Request in Account, not an Abuse Report, unless the same facts are also an unlawful disclosure of someone else’s data (in that case you may use Abuse Report and, if it also concerns data on your account, Data Request).

Account, bugs, payments: the ticket types provided. Those are not the channel for taking down content you dislike.

6.2 What to include

The clearer the file, the better staff can assess it. Give, as far as you can:

• the URL or card, or a description that lets staff find the content;
• what happened, when, and who is involved;
• why you think it breaks the Guidelines or the law (one precise line is enough);
• useful evidence: screenshots, dates, messages, documents you have the right to share.

Do not attach illegal material beyond what is strictly needed to identify the fact (in particular content involving minors: describe and report; do not multiply copies).

6.3 Abusive reports

These are themselves a breach:

• false, repeated, unfounded reports;
• using Abuse Report for a commercial dispute or to gain an advantage over a competitor;
• threatening staff or the person reported through the ticket.

ESMIRA may ignore abusive reports, limit who can file them, and take bad faith into account in the account’s history.

6.4 Authorities

A ticket does not replace a police report or an emergency call. In Cyprus, for imminent danger: the police / emergency services. ESMIRA cooperates with the authorities within the law.

7. How we assess

Staff do not apply the Guidelines as a blind checklist. They take into account, in particular:

• the text of the Guidelines and, where relevant, the Terms and applicable law;
• the content (words, images, links, the card’s context);
• context: debate, news, obvious irony, quotation in order to call something out, professional or private Space;
• reasonably inferred intent and effect on readers or on people named;
• seriousness and urgency (harm to people, minors, fraud in progress, volume);
• the account’s history (repetition, evasion, prior measures);
• informational or public-interest value, when content documents a fact, a local alert, or a criticism, without instructions to commit a crime and without exposing victims.

Irony, “parody”, and “I was joking” are not an automatic excuse. Harsh, honest criticism of a service, as the Guidelines say, is not in itself a breach.

ESMIRA is not required to try every private dispute in full (who is right in a letting, a review, a mandate). It may remove or restrict what breaks platform rules even if one party would “win” elsewhere.

8. Priority

Without a fixed time commitment (no “reply within 24 hours” in this Policy), staff will as a rule give precedence to:

1. minors, exploitation, threats of violence, safety emergencies;
2. fraud in progress, phishing, malware, impersonation of ESMIRA or of a public body;
3. hate, serious harassment, doxxing;
4. spam, misleading cards, intellectual property, other breaches;

Less urgent cases may wait. The fact that a case has not yet been handled does not mean the content has been approved.

9. Measures

If staff believe, in good faith, that there is a breach, ESMIRA may take one or more proportionate measures, including in combination:

• refuse publication, or ask for a correction before leaving the content live;
• hide, demote, or delete content (in whole or in part);
• limit features: messages, publishing, visibility, claiming cards;
• suspend an account for a period or until verification;
• close an account;
• refuse new cards or the claim of existing cards;
• intervene on a Space (content, roles, closure);
• report to the authorities;
• keep copies for legal duties, disputes, or security;
• inform a payment provider or another supplier, if the risk requires it.

Without prior notice when urgency, the law, or the risk of evasion requires it (in particular the cases in 8.1 to 8.2). In other cases staff may ask for clarification or a correction first; they are not obliged to.

A platform measure does not decide a case between private parties. An order from an authority may require broader or different steps.

10. Repeat conduct and evasion

Repeated breaches, even “small” ones, may lead to heavier measures. Dodging a suspension or closure (a new account, a stand-in, a new card) is a breach in its own right and may lead to closure and a refusal of future registrations, within the Terms.

ESMIRA may link accounts and cards when it has reasonable grounds to believe they belong to the same person or are used to get around a measure.

11. Communication

11.1 The person affected by a measure

ESMIRA may tell the member, by the means set out in the Terms (in-product notice, email on the account), that a measure was taken and, in outline, on what basis (Guidelines, Terms, law). It is not always possible or appropriate to go into detail (an investigation, minors, risk to third parties).

11.2 The person who reported

ESMIRA does not guarantee an update on every report, or a point-by-point outcome. It may confirm that the report was received. As a rule it does not disclose the identity of other parties or the full internal decision.

11.3 What we do not disclose

Investigation methods, anti-fraud signals, reporters’ identities, third-party data, and anything the law or security argue against disclosing.

12. Internal review

If you think a measure taken against you is wrong:

1. open a ticket (as a rule Abuse Report or Account Issue, depending on whether the issue is the content or access to the account);
2. give the URL or card, the approximate date, and why the measure would not sit within the Guidelines or this Policy;
3. do not open ten tickets on the same facts.

Staff may confirm, reduce, replace, or lift the measure. They may also confirm it without further debate if the facts are clear or the challenge is abusive.

This route is not a court, an arbitration, or a regulator. It does not as a rule suspend the measure, unless staff decide otherwise. Legal remedies (authorities, the courts) remain available.

This Policy does not create an automatic “second instance” or an external oversight board.

13. Spaces and admins

Anyone who administers a Space must moderate in good faith under the Guidelines. House rules of a Space do not waive the Guidelines or this Policy.

Staff may step in on a Space even if the admin does not act, or if the admin is part of the problem. They may remove content, limit roles, or close the Space.

An admin who uses the Space for hate, fraud, or exploitation is treated like any other violator, with the role as an aggravating factor.

14. Third-party rights (IP)

A credible copyright or trade-mark report may lead to removal pending verification, as the Guidelines provide. The rights holder may also act elsewhere. This Policy does not replace legal procedures.

Staff may ask the person who uploaded the content to state the basis of the right (authorship, licence). An unjustified refusal weighs in the decision.

15. Authorities and legal duties

ESMIRA may:

• give effect to a lawful order (removal, preservation, disclosure within the law);
• report facts to the authorities when it considers that due or appropriate, in particular minors and serious crime;
• keep data beyond the ordinary period if a legal duty, a dispute, or security requires it, in line with the Privacy Policy.

Someone who receives a measure because an authority asked for it may have a narrower internal review: staff cannot set aside a binding order.

16. Personal data in moderation

Reviewing reports and applying measures involves processing data (content, account, tickets, evidence). Legal basis and limits: the Privacy Policy. Reporters must not put excessive third-party data in a ticket.

Requests about your own data stay in Account (Data Request), separate from challenging a measure, even though the two paths sometimes overlap.

17. Limitations

To the extent the Terms and the law allow:

• ESMIRA does not guarantee that every breach will be seen or sanctioned;
• it does not guarantee maximum handling times;
• it does not guarantee that the service will be free of unpleasant or illegal content until it has been reported and dealt with;
• an omission or a delay is not approval of the content.

Nothing in this Policy limits mandatory consumer rights or ESMIRA’s legal duties (including, where it applies, the EU digital-services framework). If the law requires a dedicated illegal-content form or specific time limits, ESMIRA will point to them in the Legal Hub or the Terms: until then the working channel is the Abuse Report ticket.

18. Relationship with the Guidelines

• Community guidelines: what is forbidden or expected
• This Policy: how staff assess and intervene
• Terms of Service: the contract (account, liability, governing law)
• Privacy Policy: personal data

When the Guidelines are updated, later measures are assessed against the current version. Earlier facts are as a rule assessed under the rules then in force, unless the law or safety require otherwise.

19. Changes

ESMIRA may update this Policy. The current version in the Legal Hub applies, with its effective date. Archived versions remain available for history.

For material changes ESMIRA may give notice by the means set out in the Terms. Continuing to use the service after the new version takes effect counts as acceptance of the current version, to the extent the law allows.

20. Contacts

ESMIRA LTD Lambrou Katsoni, Flora Court, Block A, Office 204, 2nd Floor 8011 Paphos, Cyprus

Email: mail@esmiraweb.com Phone: +357 94 090 540

Legal Hub: Privacy Policy, Terms of Service, Cookie Policy, Community guidelines, this Policy.

Conduct reports: Abuse Report ticket. Personal data: Data Request in Account.