Moderation, Complaints & Appeals Procedure

Version: Launch Suite vL1 (rev. 8.1) · Effective date: 29 September 2026

Steelo Labs Ltd — Steez platform

Plain-English summary This document explains how to raise a complaint about Steez, what happens when we moderate content or accounts, and how to appeal a decision you think is wrong. We are required by law (the Online Safety Act 2023) to have this procedure. We will acknowledge your complaint as soon as reasonably practicable and, in any event, without undue delay, and aim to resolve it promptly. To appeal a decision, you contact us by email (clause 6) — we do not yet have a self-serve in-app appeals button, so the email route is the live route. Steez's paid services are offered in the UK and US at launch, so this procedure signposts US privacy rights (clause 11); it also sets out the EU/EEA appeal and statement-of-reasons rights required by the EU Digital Services Act (clause 12A) for when Steez is offered there. It covers complaints about buying a Steez (clause 6A), data-protection complaints (Privacy Policy cross-ref), and the deadlock notice we give you if we cannot resolve your complaint and you wish to consider alternative dispute resolution.

1. Definitions

In this Procedure the following words have the meanings set out below. Capitalised terms used here but not defined here carry the meaning given in the Terms of Service or, for creator-specific matters, the Creator Terms & Earnings Agreement.

2. Scope of this Procedure

2.1 This Procedure applies to all of the following:

(a) complaints about content on the Platform that a Complainant believes is illegal, harmful, or in breach of the Acceptable Use & Community Guidelines;

(b) complaints about a Content Decision that a Complainant believes was wrongful — for example, content the Complainant uploaded or posted that was removed, labelled, restricted, demoted, suspended, or disabled in a way they consider incorrect;

(c) complaints about an Account Action — including a mute (whether global or community-level), a suspension, or a ban — that a Complainant believes was unwarranted or disproportionate;

(d) complaints about the actions of a creator acting as a community moderator within a Village, where those actions are alleged to be abusive or outside the scope of the creator's permitted moderation powers (see clause 7);

(e) complaints alleging that Steelo Labs Ltd has failed to comply with its duties under the OSA, including duties relating to illegal content, harmful content, content-reporting mechanisms, or this Procedure itself;

(f) complaints about the purchase of a Steez — see clause 6A;

(g) data-protection complaints — see clause 11;

(h) creator complaints about our handling of their account, revenue, or content, including P2B-style complaints — see clause 10; and

(i) for EU/EEA Users, complaints and appeals under the DSA, including challenges to a Statement of Reasons — see clause 12A.

2.2 This Procedure does not replace or limit your rights under the Refund & Cancellation Policy, your statutory rights under the Consumer Rights Act 2015 and the Consumer Contracts Regulations 2013 (or the equivalent mandatory consumer-protection law of your country of residence), or your right to bring a claim in court. Your statutory consumer rights — including statutory refund and cancellation rights — are honoured immediately and unconditionally, and nothing in this Procedure delays or withholds a statutory remedy you are entitled to.

2.3 If you are a creator raising a dispute about earnings, Stripe payouts, or fee deductions, the first escalation route is our internal complaint process under clause 6, then the courts as set out in clause 12. See also the Creator Terms & Earnings Agreement.

2.4 Steez's paid services are offered in the UK and US at launch (Terms of Service §2.1). Where the law of your country of residence gives you mandatory complaint, appeal, dispute-resolution, or consumer-protection rights that cannot lawfully be excluded by agreement, those rights prevail over anything in this Procedure to the extent of any conflict, and this Procedure operates in addition to them, not instead of them.

3. How to Report Content or Raise a Complaint

What this section says: There are two ways to report content or raise a formal complaint — in the app/website, or by email. Both are valid. An in-app report about content is the fastest route. A formal Complaint (about a decision already made, our conduct, or a purchase of a Steez) should be submitted by email so we have a clear written record.

3.1 In-app and in-platform reporting

3.1.1 For any piece of content (a post, video, comment, community chat message, or direct message) you believe is illegal, harmful, or in breach of our Acceptable Use & Community Guidelines, use the in-app report function:

• On a post or video: tap the three-dot (⋯) menu and select Report.
• On a comment: long-press the comment and select Report.
• On a community chat message: long-press the message and select Report.
• On a direct message: long-press the message and select Report.
• On a user profile: tap the three-dot (⋯) menu on the profile and select Report.

3.1.2 For ordinary in-app community reports, you will be asked to select a reason from the following categories: Spam; Harassment; Inappropriate Content; Scam/Fraud; Other. You may also provide up to 500 characters of free-text detail. This short in-app menu is not exhaustive and does not limit the uncapped routes for illegal content, OSA complaints, DSA Article 16 notices, copyright or other rights-holder notices, imminent harm or other safety risks, CSAM or intimate-image abuse, scam/fraud reports, or reports by affected non-users.

3.1.3 Submitted reports are sent to our moderation queue and reviewed by our team. A rate limit of 20 reports per user per day applies to prevent abuse of the ordinary community-reporting system. This rate limit does not apply to reports of illegal content, child sexual abuse material (CSAM), intimate-image abuse, copyright infringement, fraud or scams, content posing a risk to safety, OSA complaints, DSA Article 16 notices, or reports by affected non-users — reports in these categories are always accepted and are never blocked or rate-limited.

3.1.4 If you are a non-user (for example, you are depicted in content on the Platform but do not have an account), you may still submit a report by email using the contact details in clause 3.2 below. You are not required to create an account to report content under the OSA, or — if and when Steez is offered in the EU/EEA — to submit a notice under the DSA notice-and-action mechanism (clause 12A).

3.2 Formal Complaint by email

3.2.1 For a formal Complaint — including a Complaint about a Content Decision already made, an Account Action taken against you, creator-moderator conduct, a Steez purchase (clause 6A), or alleged non-compliance with OSA or DSA duties — please email:

legal@steez.space

3.2.2 Please include in your Complaint:

(a) your full name and the email address registered to your Steez account (if applicable);

(b) a clear description of what you are complaining about, including the content, account, or transaction involved (URLs, order references, or screenshots are helpful);

(c) what you would like us to do to resolve the Complaint; and

(d) if you are not a registered user, your name and contact email address.

3.2.3 We may ask for further information to process your Complaint. We will not share your identity with any user whose content or actions your Complaint concerns, except to the minimum extent necessary to investigate and resolve the matter or as required by law.

4. Content Moderation: What We Do and How

What this section says: We have a moderation team that reviews reported content. We also have an automated rule engine in community chat. Posts and images are NOT automatically scanned — only community chat messages have automated checks. Bans and mutes are applied by our moderation team; creators can also moderate their own Villages within the limits we describe in clause 7.

4.1 Steelo Labs operates a moderation system that includes the following tools and processes:

(a) Human review queue: All in-app reports go to a moderation queue reviewed by authorised Steelo Labs staff. Staff have the ability to dismiss a report, mark it as reviewed, action it by removing or restricting content, or warn a user.

(b) Automated community chat moderation: Community chat messages in Villages are processed by an automated rule engine that checks for banned words (set by the creator for their Village), spam (duplicate message detection), and link domain filtering. This automated processing is disclosed here and in our Privacy Policy. Posts, videos, and images are NOT subject to automated scanning.

(c) Creator-moderation in Villages: Creators and their designated team and moderator roles can mute members within their Village. See clause 7 for the scope and limits of creator-moderator powers.

4.2 Account Actions we may take:

4.3 We maintain a moderation audit log (`_moderation_audit`) for all enforcement actions. This supports our OSA record-keeping obligations under OSA s.23 and Ofcom's Codes of Practice. Moderation records are retained on a tiered schedule by category and seriousness — dismissed reports and low-level warnings for a short operational period, more serious or repeated matters for longer, and records under a legal hold, statutory report, or regulatory requirement for as long as that purpose requires — as set out in the Privacy Policy and Data Deletion Policy. We do not use six years as a default for every action.

4.4 If you believe an Account Action has been taken against your account, contact us at the email address in clause 3.2 and we will confirm the position within 5 Working Days. This Procedure sets out your rights to complain and appeal. Where you are an EU/EEA User, a Content Decision or Account Action that restricts your content or account will also be accompanied by a Statement of Reasons under clause 12A.

4.5 A permanent account ban revokes login and access to the Platform. A ban does not automatically forfeit the paid one-off entitlements (Steez Keys and content unlocks) you hold. Access to a specific paid entitlement is disabled only where that entitlement is connected to the violation that led to the ban, or where continuing to provide it would be unlawful — and even then only to the extent proportionate. Where an entitlement is not connected to the violation and remains lawful to provide, we will offer you, in line with the Data Deletion Policy §4.2, either (a) preservation of that entitlement — including, where the ban leads to closure of your account, a secure single-use re-link token that lets you redeem the preserved entitlement on a new account — or (b) an appropriate refund for access you have paid for but will lose. Your statutory consumer rights are unaffected. If you believe a ban was wrongful, you may complain and appeal under clauses 6 and 6A; a successful appeal restores your access.

5. Acknowledgement and Resolution Timescales

What this section says: We will acknowledge your Complaint as soon as reasonably practicable and, in any event, without undue delay, and we aim to resolve most complaints promptly. These are genuine targets, not hard contractual deadlines.

5.1 On receipt of a formal Complaint by email (clause 3.2), we will:

(a) send you an acknowledgement as soon as reasonably practicable and, in any event, without undue delay, confirming we have received your Complaint and giving you a reference number; and

(b) use reasonable efforts to resolve the Complaint and send you a decision typically within 30 days of acknowledgement.

5.2 Complex complaints — for example, those involving third-party rights, legal proceedings, OSA-duty questions, or a contested purchase transaction — may take longer than 30 days. If we need more time, we will tell you within the 30-day window, explain why, and give you an expected resolution date.

5.3 These timescales are targets, not hard contractual deadlines. We do not waive any legal obligations by setting out these targets. Where the DSA or a local mandatory law imposes a shorter or specific timescale (for example, expeditious handling of illegal-content notices), we will comply with that timescale.

5.4 In-app reports (clause 3.1) do not carry an acknowledgement obligation but are reviewed as promptly as our moderation capacity allows. We do not promise any specific turnaround on in-app reports, save that illegal-content notices and DSA notices (clause 12A) are handled in a timely, diligent, non-arbitrary, and objective manner.

6. Our Decision and Your Appeal Rights

What this section says: When we make a decision on your Complaint, we will tell you what we decided and why. If you disagree, you can ask for a human review (an appeal) by contacting us. Appeals are reviewed by a senior person who was not involved in the original decision.

6.1 Complaint decision: When we have investigated your Complaint, we will send you a written decision stating:

(a) the outcome (uphold, partially uphold, or not uphold);

(b) the reasons for that outcome; and

(c) what action (if any) we will take or have taken.

6.2 Appeals — right to request:

6.2.1 If you are not satisfied with the Complaint decision, you may request an appeal by contacting us in writing (by email under clause 3.2) within 30 days of receiving the decision. Your appeal request should state clearly why you believe the decision was wrong and any new information you wish us to consider. (For EU/EEA Users, the internal-complaint-handling appeal window under the DSA is at least six months — see clause 12A.3.)

6.2.2 Appeals are reviewed by a senior Steelo Labs representative who was not involved in making the original decision. Where the original decision was made by a junior team member, the appeal reviewer will be more senior.

6.2.3 The appeal reviewer may:

(a) confirm the original decision;

(b) overturn the original decision (in whole or in part) and take corrective action, which may include reinstating content, removing a mute, lifting a ban, or issuing a revised Content Decision; or

(c) request further information before making a final appeal determination.

6.2.4 We will send you the appeal outcome typically within 30 days of receiving your appeal request. As with clause 5.2, complex appeals may take longer; we will inform you if so.

6.3 Appeal mechanism — current state: A dedicated in-app or in-product appeal mechanism is not currently offered. Appeals are therefore made by contacting us by email under clause 3.2 — that is the live appeals route. We do not currently offer a self-serve in-product appeals button. We will keep this Procedure under review and will update it if and when an in-product appeals route is introduced. We do not promise a date for that route here.

6.4 Human review commitment: All appeals are reviewed by a human. We do not use solely automated decision-making to determine appeals.

6A. Steez Purchase Complaints

What this section says: A Steez is a personal access key giving access only to what a creator offers. It is not a financial asset, security, or investment. You buy a Steez first-hand; it is non-transferable and non-resellable. If something goes wrong with a purchase, you can complain under this clause, and your statutory consumer rights are unaffected.

6A.1 What a Steez is. A Steez is a personal access key giving access only to what a creator offers (Mosaic exclusives, Village community, and creator-picked Perks); it is personal, non-transferable, and non-resellable. A Steez is not a financial asset, security, investment, e-money, stored value, deposit, trust asset, ownership interest, share in Steelo Labs, or share in creator or platform revenue, and carries no guaranteed or realisable monetary value. We never promise, validate, certify, or guarantee any value, return, or future price. The Terms of Service and Refund & Cancellation Policy set out the full purchase and risk terms.

6A.2 First-hand purchases. A first-hand Steez is sold at a fixed first-hand price of £30 (GBP), whichever device you use, with Steelo Labs as the seller. If a first-hand purchase was not delivered, was not as described, was charged incorrectly, or was otherwise faulty, you may complain under clause 3.2 and exercise your statutory rights under the Consumer Rights Act 2015 and the Consumer Contracts Regulations 2013 (clause 2.2). Your statutory remedy is honoured immediately and unconditionally and is never delayed by any internal creator-fault/platform-fault allocation.

6A.3 Routing. Purchase complaints are handled under the timescales in clause 5 and the appeal route in clause 6, and (for EU/EEA Users) alongside the DSA rights in clause 12A where a content or account decision is also involved.

7. Creator-Moderated Villages: Powers, Limits, and Complaints

What this section says: Creators can moderate their own Villages — they can mute members and remove messages. Their powers are limited to their own Village; they cannot ban anyone from the whole platform. If you think a creator has abused their moderation powers, you can complain to us.

7.1 Creators and their designated moderators (team and moderator roles) may take the following actions within their own Village:

(a) mute a member within the Village (for a period they set, which may be indefinite);

(b) remove individual community chat messages; and

(c) set community moderation rules (banned words, spam filters, link blocking).

7.2 Creator-moderators do NOT have the ability to:

(a) ban a user from the Steez platform globally (that power belongs solely to Steelo Labs administrators);

(b) access or modify the accounts, payment data, or personal information of Village members; or

(c) take moderation action outside their own Village.

7.3 Creators act independently when exercising their moderation powers in their Village. Steelo Labs is not responsible for the individual moderation decisions of creators, provided those decisions are made within the powers described in clause 7.1. This does not exclude Steelo Labs' own responsibility: we retain and operate the moderation tools, provide the complaint and appeal route in clause 6, reserve the right to review and reverse any creator-moderation action that breaches these terms or applicable law, and remain responsible for our own negligence and for any statutory duty (including our duties under the OSA and, where applicable, the DSA) that cannot lawfully be excluded. This mirrors the standard in the Acceptable Use & Community Guidelines §14B.5. A creator who abuses their moderation powers in a way that is unlawful or in breach of the Acceptable Use & Community Guidelines may themselves be subject to Account Actions by Steelo Labs.

7.4 If you believe a creator has abused their moderation powers in a Village — for example by targeting you on a discriminatory basis, by systematically suppressing legitimate speech, or by acting outside the scope of clause 7.1 — you may raise a formal Complaint under clause 3.2. We will investigate and, where warranted, take action against the creator's account.

7.5 Steelo Labs does not operate a dedicated warnings or progressive-discipline system for ordinary moderation actions at the platform level. Enforcement follows the ladder in clause 4.2. The Acceptable Use & Community Guidelines describe prohibited conduct; the absence of a prior warning does not prevent us from taking immediate action where content or conduct is seriously harmful or illegal.

8. Illegal Content and OSA Duty Complaints

What this section says: The Online Safety Act 2023 requires us to have a complaints process. If you think we have failed in our legal duties — for example, by not acting on illegal content you reported — you can tell us and we must take the complaint seriously.

8.1 The Online Safety Act 2023 (OSA) imposes duties on Steelo Labs as a regulated user-to-user service. These include:

(a) maintaining accessible in-product reporting mechanisms for illegal content and content harmful to children (OSA s.20);

(b) maintaining this Complaints Procedure (OSA s.21); and

(c) taking proportionate measures to prevent priority illegal content and to act swiftly on awareness (OSA s.10).

8.2 If you believe Steelo Labs has failed to comply with its OSA duties — for example, by failing to remove illegal content after a report, by not providing an accessible reporting mechanism, or by acting inconsistently with our published policies — you may raise a formal Complaint under clause 3.2 stating that your Complaint concerns an OSA-duty failure.

8.3 OSA-duty complaints will be escalated to the Senior Accountable Person and will be treated with priority. We will investigate whether our systems and processes met their statutory obligations and respond to you under the timescales in clause 5.

8.4 Escalation to authorities (DSA Article 18). Where information about content or activity gives rise to a suspicion of a criminal offence involving a threat to the life or safety of a person, we will promptly inform the appropriate Member State law-enforcement or judicial authority or Europol (for EU/EEA matters), and the relevant UK authority, and provide the information available to us. This is separate from, and additional to, our handling of priority illegal content (clause 3 and Acceptable Use Part 3).

8.5 Categories of priority illegal content under the OSA (and the Illegal Content Codes of Practice) that we are required to tackle include: child sexual abuse material (CSAM); terrorism content; fraud and financial harm; intimate-image abuse; harassment; incitement to violence; and other offences listed in OSA Schedule 7 as amended. Our Acceptable Use & Community Guidelines and the proscribed-content list in our Terms of Service set out the specific prohibited content categories in full. Adult content is prohibited on the Platform.

8.6 Steelo Labs keeps written records of risk assessments and measures taken under the OSA Codes of Practice, as required by OSA s.23, so that we can demonstrate compliance to Ofcom if required.

9. Children and Accessibility

9.1 Age posture: Steez is strictly for users aged 18 and over. At signup we record an express 18+ attestation; proportionate additional age assurance is planned. Our age posture is described in the Terms of Service and the Privacy Policy. Until highly effective age assurance is fully in place, we treat this procedure as accessible to any user, including a child, in line with our OSA obligations. Our OSA risk assessments — including the children's-access assessment — are in progress and are not yet complete. We will not offer account registration or payment features until the children's-access assessment has been completed.

9.2 We write this Procedure in plain, clear English. If you have difficulty understanding any part of it, please contact us at the email address in clause 3.2 and we will do our best to assist.

9.3 If despite our 18+ posture a child has accessed the Platform and is the subject of, or wishes to raise, a complaint, they may be assisted by a parent or guardian who may submit the Complaint on their behalf.

10. Creator Complaints (P2B-Style)

What this section says: Creators can use this same procedure to complain about decisions we make that affect their account, content, or earnings. We treat creator complaints seriously even though we are currently a small company. Courts are open to all creators — we do not impose arbitration.

10.1 Creators may use this Procedure to raise complaints about any of the following:

(a) removal or restriction of their content or creator profile;

(b) suspension or termination of their creator account;

(c) changes to fee arrangements, ranking parameters, or platform policies that affect them, where they believe those changes were made without adequate notice or justification;

(d) disputes about royalties — including the 80% royalty on creator subscriptions, content collections, and first-hand Steez sales, calculated by reference to the net price; and

(e) any other decision by Steelo Labs that materially affects their ability to operate as a creator on the Platform.

10.2 Steelo Labs operates an internal complaint-handling process available to creators free of charge, as described in clauses 3–6 of this Procedure. As a small enterprise under the UK P2B Regulation (SI 2020/609) (fewer than 50 staff, and annual net turnover or annual balance sheet total not exceeding €10 million), Steelo Labs is currently exempt from both the requirement to provide a formal internal complaint-handling system (P2B Article 11) and the requirement to identify mediators (P2B Article 12). We nonetheless operate this internal process voluntarily while that exemption applies, and we will put in place a fully Article 11-compliant system and named Article 12 mediation options if and when the exemption ceases to apply.

10.3 The Creator Terms & Earnings Agreement sets out specific terms for content removal, account termination, royalty rates, refund cost-attribution, and the effects on earned but unsettled funds. This Procedure applies alongside, and does not modify, those terms. As principal seller, Steelo Labs bears ordinary refunds and chargebacks; a refund cost is recovered from a creator only to the extent it was caused by that creator's breach, fraud, misdescription, or warranty failure, and only after we give the creator the evidence relied on and a fair opportunity to challenge the allocation (Creator Terms & Earnings Agreement clauses 10.1 and 11.4). A creator who believes a refund arose from platform-fault, or who disputes an allocation, may raise a dispute under this Procedure. This internal cost-attribution never delays or reduces the consumer's statutory remedy.

10.4 Courts, not arbitration: Steelo Labs does not require creators to use arbitration to resolve disputes. All creators — whether acting as a business or as a consumer — retain the right to bring a claim in the courts of England and Wales on a non-exclusive basis, or (for consumers) in the courts of their country of habitual residence. London arbitration is reserved for true business-to-business contracts only and is never imposed on consumers or individual hobbyist creators.

11. Data-Protection Complaints

What this section says: If your complaint is about how we use your personal data, you can complain to us directly. If we do not resolve it to your satisfaction, you have the right to complain to the Information Commissioner's Office (ICO), and (in the EU/EEA) to your local supervisory authority.

11.1 If your Complaint concerns how Steelo Labs has handled your personal data — including a request to access, correct, or delete your data, or a concern about how your data is being used — please refer in the first instance to our Privacy Policy, which explains your rights and how to exercise them. Where a self-serve route is not yet built, you can exercise these rights by contacting us at our named privacy contact, privacy@steez.space. We have not appointed a formal Data Protection Officer.

11.2 You may also raise a data-protection concern as a Complaint under this Procedure using the contact details in clause 3.2. Mark your email clearly as a "Data Protection Complaint".

11.3 If we cannot resolve your data-protection complaint to your satisfaction, you have the right to complain to the Information Commissioner's Office (ICO):

• Website: www.ico.org.uk
• Telephone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

We are registered with the Information Commissioner's Office (registration reference ZB826048).

11.4 Section 164A of the Data Protection Act 2018 (in force since 19 June 2026) gives you the right to make a data-protection complaint to us as the controller: we will acknowledge your complaint within 30 days and respond without undue delay. This is separate from your right to complain to the ICO, which arises under Article 77 UK GDPR and section 165 of the Data Protection Act 2018. You do not need to exhaust our internal process before complaining to the ICO, but we ask that you give us the opportunity to address your concern first.

11.5 Data-protection concerns about our moderation practices — for example, about the retention of moderation audit logs or violation records (retained 6 years) — will be handled under both this Procedure and our obligations under UK GDPR. Our Privacy Policy sets out the lawful bases and retention periods for moderation-related data.

11.6 EU/EEA Users: If you are an EU/EEA User, the EU General Data Protection Regulation (GDPR) applies to the processing of your personal data. We are in the process of appointing an EU Representative under Article 27 GDPR; until appointed, you can raise any data-protection matter with us directly at privacy@steez.space. You also have the right to lodge a complaint with the supervisory authority in your country of residence or place of the alleged infringement, in addition to any rights under clauses 11.1–11.4.

11.7 US Users: If you are a resident of a US state with applicable privacy legislation, you may have rights under the California Consumer Privacy Act / California Privacy Rights Act and comparable state laws (for example, to access, delete, correct, or opt out of certain processing of your personal information). Our Privacy Policy explains how to exercise those rights.

12. Deadlock and Alternative Dispute Resolution

What this section says: If we have gone through our full complaints process and you are still not satisfied, we will tell you in writing. At that point, you can consider taking your complaint to a court or to an accredited alternative dispute resolution (ADR) provider. We are not currently obliged to use ADR, but we will signpost you to accredited options.

12.1 If your Complaint has been through our full internal process (including any appeal under clause 6) and remains unresolved to your satisfaction, we will send you a deadlock notice on a durable medium (email) stating:

(a) that we have been unable to resolve the Complaint through our internal process;

(b) where the law requires us to identify an ADR body, or where a suitable accredited body is competent and available for the dispute, its name and contact details (under the DMCCA 2024 Part 4 Chapter 4 regime, in force 6 April 2026), and whether we are required or prepared to use it; and

(c) whether Steelo Labs is obliged or prepared to use that ADR provider.

12.2 We will not include an EU Online Dispute Resolution (ODR) platform link — the EU ODR platform was discontinued on 20 July 2025 and no longer exists. (EU/EEA Users' out-of-court dispute-settlement rights under the DSA are set out separately in clause 12A.4.)

12.3 Courts: You retain the right at all times to bring a claim in the courts of England and Wales on a non-exclusive basis. Governing law is English law. If you are a consumer, English law applies in addition to any mandatory protections of the law of your country of habitual residence, and you may also bring a claim in the courts of the country where you live. We do not impose mandatory arbitration, exclusive jurisdiction, or class-action waivers on consumers.

12.4 Nothing in this clause limits your statutory rights or your right to complain to a regulator.

12A. EU/EEA Users: Digital Services Act Rights

What this section says: Steez's paid services are not offered in the EU/EEA at launch. If and when Steez is made available there, the EU Digital Services Act will give EU/EEA users extra rights: you can send us a notice about illegal content, you get a written explanation when we restrict your content or account, you can appeal that decision to us for at least six months, and you can use an out-of-court dispute-settlement body.

This clause 12A describes the rights the EU Digital Services Act will give EU/EEA Users if and when Steez is made available in the EU/EEA (not at launch — see Terms of Service §2.1).

12A.1 Notice-and-action mechanism (DSA Art 16): If and when Steez is offered in the EU/EEA, any individual or entity may notify us of content on the Platform they consider to be illegal. Notices may be submitted through the in-app report function (clause 3.1) or by email to legal@steez.space. To be effective, a notice should include: a sufficiently substantiated explanation of why the content is illegal; the precise location (e.g. URL) of the content; the notifier's name and email (except for notices concerning certain child-sexual-abuse or related offences); and a statement of good-faith belief that the notice is accurate and complete. We will confirm receipt without undue delay, process notices in a timely, diligent, non-arbitrary, and objective manner, and notify the notifier of our decision and available redress.

12A.2 Statement of Reasons (DSA Art 17): If and when Steez is offered in the EU/EEA, where we restrict a recipient's content or account in a way that affects an EU/EEA User — including removing, disabling, demoting, or restricting visibility of content, suspending or terminating provision of the service, suspending or terminating an account, or imposing any monetary, monetisation, or payout restriction (for example demonetising content, or withholding, suspending, or reducing payouts) — we will provide that user with a clear and specific Statement of Reasons. It will set out: the action taken and its scope and duration; the facts and circumstances relied on; whether automated means were used; the legal or contractual ground relied on and an explanation of why the content is considered illegal or incompatible with our terms; and the redress options available, including internal complaint handling (clause 12A.3), out-of-court dispute settlement (clause 12A.4), and judicial redress (clause 12.3).

12A.3 Internal complaint-handling system (DSA Art 20): Steelo Labs currently qualifies as a micro or small enterprise and is therefore exempt from the obligations in Section 3 of Chapter III of the DSA — which include Article 20 (internal complaint-handling) and Article 21 (out-of-court dispute settlement) — under DSA Article 19. We nonetheless offer the following voluntarily while that Article 19 exemption applies, and the Article 20 / Article 21 obligations would become mandatory if the exemption ceases (for example on growth beyond the threshold) or on designation as a Very Large Online Platform. This Article 19 exemption is limited in scope: it does not affect our duties under Articles 16–18 (notice-and-action, statements of reasons to affected users, and notification of suspicions of criminal offences involving threats to life or safety), which continue to apply; it does not cover Article 24(3) (reporting average monthly active recipients to the Digital Services Coordinator or the Commission on request), which continues to apply to us; the separate Article 24(5) duty to submit statements of reasons to the Commission's DSA Transparency Database does not apply while we qualify for the Article 19 exemption, though we may submit voluntarily; and where we cease to qualify as a micro or small enterprise the exemption continues for only a further 12 months, and does not apply at all once we are designated a Very Large Online Platform. As a voluntary matter: for at least six months after a decision described in clause 12A.2, an affected EU/EEA User may lodge a complaint against that decision through our internal complaint-handling process, free of charge, using the appeal route in clause 6 (by contacting us by email per clause 3.2). We will handle such complaints in a timely, non-discriminatory, diligent, and non-arbitrary manner, reverse the decision without undue delay where the complaint shows the content is not illegal or incompatible with our terms or otherwise that the decision was wrong, and ensure complaints are decided under the supervision of appropriately qualified staff and not solely by automated means.

12A.4 Out-of-court dispute settlement (DSA Art 21): As noted in clause 12A.3, Article 21 falls within the DSA Article 19 micro/small-enterprise exemption and does not currently bind us; we describe it here because we will signpost it voluntarily and it becomes mandatory if that exemption ceases. EU/EEA Users who are dissatisfied with the outcome of, or otherwise affected by, a decision under clause 12A may select any out-of-court dispute-settlement body that has been certified by the Digital Services Coordinator of an EU Member State to resolve their dispute. Such bodies are listed by the relevant Digital Services Coordinator. Recourse to such a body does not affect the right to bring proceedings before a court. We will engage in good faith with any certified body so selected, as required by the DSA.

12A.5 EU legal representative (DSA Art 13): Steelo Labs Ltd will designate a legal representative in a Member State where it offers its services, who can be addressed in relation to DSA matters.

12A.6 The rights in this clause 12A are in addition to, and do not limit, any other rights in this Procedure or under the mandatory law of your country of residence (clause 2.4).

13. Confidentiality and Transparency

13.1 We treat all Complaints in confidence. We will not disclose the identity of a Complainant to the subject of a Complaint (for example, a creator or other user) except to the minimum extent necessary to investigate the matter or as required by law.

13.2 We keep records of complaints and appeals for the purposes of:

(a) improving our moderation and safety practices;

(b) meeting our OSA record-keeping obligations under s.23; and

(c) demonstrating compliance to Ofcom or other regulators (and, for EU/EEA matters, providing Statements of Reasons to the DSA Transparency Database) if required.

13.3 We do not publish individual complaint decisions. Aggregate information about moderation actions may be included in any transparency reports we produce.

14. Changes to this Procedure

14.1 We may update this Procedure from time to time — for example, to reflect changes in our moderation tooling, changes in our purchase features, changes in law (including OSA Codes of Practice updates and DSA guidance), or improvements to our complaints process.

14.2 We will publish the updated Procedure on our website and, if the change is material, notify registered users via the email address on their account with at least 15 days' notice before the change takes effect (consistent with the UK P2B Regulation, Art 3(3), and good practice for consumer-facing terms).

14.3 If you disagree with a change to this Procedure that affects you as a creator, you may raise a Complaint under clause 10 within the 15-day notice period.

15. Contact Details and Responsible Person

15.1 All formal Complaints under this Procedure should be directed to:

Email: legal@steez.space — this is our single nominated address for formal complaints and appeals. General enquiries sent to support@steez.space are routed internally to the same team, so you will not lose your place by using either address.

Post: Steelo Labs Ltd (company number 15553648), 3 Harebell Close, Hamilton, Leicester, England, LE5 1UX

15.2 The Senior Accountable Person for OSA compliance is Edmund Berkmann, Founder.

15.3 For data-protection queries specifically, contact privacy@steez.space. An EU/EEA Art 27 GDPR Representative is in the process of being appointed; until appointed, EU/EEA Users should use privacy@steez.space and we will deal with the matter directly.

16. Related Documents

This Procedure should be read alongside the following documents, all of which are published on the Steez platform:

• Terms of Service
• Creator Terms & Earnings Agreement
• Privacy Policy
• Cookie & Tracking Policy
• Acceptable Use & Community Guidelines
• Data Deletion Policy
• Refund & Cancellation Policy
• Copyright & Takedown Policy
• Website Terms of Use

The complaints route for copyright takedown disputes is set out in the Copyright & Takedown Policy. If a complaint involves both a content-moderation question and a copyright question, we will handle the copyright aspect under the Copyright & Takedown Policy and the moderation/OSA aspect under this Procedure. Copyright and rights-holder claims are dealt with through our reports and formal dispute-resolution process: creators warrant to Steelo Labs that they own or control all rights in the music and other Content they post and are responsible to Steelo Labs for it; nothing in this excludes or limits Steelo Labs' own non-excludable statutory duties, its notice-and-action obligations once it becomes aware of infringing or unlawful Content, or any liability that cannot lawfully be excluded; the availability of any hosting or intermediary defence is assessed function-by-function and item-by-item; Steelo Labs retains takedown and revenue-clawback rights. Complaints about the purchase of a Steez are handled under clause 6A.

Steelo Labs Ltd — Registered in England and Wales, company number 15553648. Registered office: 3 Harebell Close, Hamilton, Leicester, England, LE5 1UX. Company domain steelo.io; product domain steez.space.