Copyright & Takedown Policy

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

Document title: Copyright & Takedown Policy

Governing law: England and Wales Operator: Steelo Labs Ltd, England & Wales — registered office: Steelo Labs Ltd, 3 Harebell Close, Hamilton, Leicester, England, LE5 1UX Company number: 15553648 Contact for IP and notice-and-action matters: legal@steez.space

Contents

1. About this Policy
2. Definitions
3. Our Hosting Position, IP Ethos and Approach to Monitoring
4. Copyright Infringement Notices: How to Report
5. What Happens After We Receive a Copyright Notice
6. Counter-Notices: Disputing a Takedown
7. Repeat-Infringer Policy
8. Takedown Log and Record-Keeping
9. Music-Specific Guidance
10. Share-Clip Distribution
11. Trademark and Impersonation Reports
12. Defamation and Other Non-Copyright Complaints
13. EU Digital Services Act: Notice-and-Action and Statement of Reasons
14. US DMCA Notices and International Notices
15. Liability, Good Faith and Your Statutory Rights
16. Contact Details

1. About this Policy

What this section says

This policy explains how Steelo Labs Ltd operates the Steez platform's notice-and-takedown process for intellectual-property and other content complaints. It sets out the information a rightsholder must provide when making a report, what we will do with that report, what options an uploader has to dispute a removal, how we treat users who infringe repeatedly, and how rightsholders, users and regulators in every jurisdiction where Steez is available can reach us. Steez's paid services are offered in the UK and US at launch, so this policy sets out the routes for the UK and US (and the EU/EEA and elsewhere as we expand to those territories).

1.1 Steelo Labs Ltd ("Steelo Labs", "we", "us") operates the Steez creator-and-fan platform ("Steez" or the "Platform"), accessible at steez.space (and at steelo.io) and through the Steez mobile applications.

1.2 Creators upload content — including videos, images, articles, and chat attachments — to the Platform. We respect the intellectual property rights of third parties and require our users to do the same. Where content infringes copyright, trademark, or other intellectual-property rights, we will act expeditiously to investigate and, where appropriate, remove, disable, or restrict access to it.

1.3 This policy sits alongside and should be read together with our:

• Terms of Service
• Creator Terms & Earnings Agreement
• Acceptable Use & Community Guidelines ("AUP")
• Moderation, Complaints & Appeals Procedure
• Privacy Policy

1.4 Steez's paid services are offered in the UK and US at launch (Terms of Service §2.1). Nothing in this policy limits or excludes any rights you have under applicable law, including those available under the Copyright, Designs and Patents Act 1988 ("CDPA"), the Electronic Commerce (EC Directive) Regulations 2002 ("E-Commerce Regulations"), or the Online Safety Act 2023 ("OSA"). Mandatory-rights saver: where the mandatory law of the country in which you are habitually resident gives you rights or protections (as a consumer, as a rightsholder, or otherwise) that cannot lawfully be excluded and that are more favourable to you than this policy, those mandatory rights prevail to the extent of any conflict. In particular, EU/EEA users have the additional rights set out in section 13 (Digital Services Act), and US users have the rights summarised in clause 14.4.

2. Definitions

"AUP" means our Acceptable Use & Community Guidelines, including the hard prohibition in AUP §8.1 on label-owned master recordings and unlicensed third-party recordings.

"Claimant" means a rightsholder (or their authorised representative, including a collecting society or other rights-management organisation acting for its members) who submits a notice of alleged infringement.

"Content" means any video, image, text, article, clip, or other material uploaded to or transmitted via the Platform by users.

"Counter-Notice" means a written statement by an Uploader disputing that reported Content infringes the Claimant's rights, submitted in accordance with section 6.

"Creator" means a user who has activated a creator account on the Platform and uploads Content.

"DMCA" means the US Digital Millennium Copyright Act (17 U.S.C. § 512).

"DSA" means Regulation (EU) 2022/2065 (the Digital Services Act).

"Exclusive Content" means Content (such as a Mosaic exclusive, Village community material, or a creator-picked Perk) that a Creator gates behind a Steez key, a subscription, or a content-collection purchase.

"Fan" means a user who consumes Content on the Platform.

"Notice" means a written infringement report submitted to us under section 4 (and, for EU/EEA users, the notice-and-action submission described in section 13).

"Platform" has the meaning given in clause 1.1.

"PRO" means a performing-rights or rights-management organisation or collecting society anywhere in the world (for example PRS for Music, MCPS or PPL in the UK; ASCAP, BMI or SESAC in the US; GEMA, SACEM or equivalents in the EU).

"Share-Clip" means a short, watermarked clip of non-Exclusive Content generated by the Platform for external distribution by Fans or Creators.

"Statement of Reasons" means the explanation we provide under the DSA when we restrict Content or an account, as described in section 13.

"Steez key" (or "Steez") means the personal licence a Fan obtains — personal, non-transferable, and non-resellable — to access only what a Creator explicitly offers (such as Mosaic exclusives, Village community access, and creator-picked Perks); it 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 confers no ownership of any Content. It carries no guaranteed or realisable monetary value.

"Takedown" means the removal, disabling, or restriction of access to Content following a valid Notice or our own assessment.

"Uploader" means the user who uploaded or posted the Content that is the subject of a Notice or Takedown.

3. Our Hosting Position, IP Ethos and Approach to Monitoring

What this section says

We store content uploaded by users, and to that extent we act as a host. But some of what we do — curating, paywalling, applying DRM to, and distributing content (including the main stream and externally distributed share-clips) — goes beyond passive hosting, and we do not claim a blanket hosting defence for it. We do not proactively scan video uploads or images for copyright infringement. Our community-chat rule engine checks chat messages against specific rule sets, but that system does not perform copyright detection. We do not take ownership of creator music and do not hold a collective PRO/CMO licence unless expressly stated — creators are responsible for what they post. We act expeditiously on a valid notice.

3.1 Hosting position — to the extent we act as host. In respect of Content that Creators upload to the Platform, and to the extent that our activity in relation to that Content is the storage of information provided by a recipient of the service, Steelo Labs acts as a hosting provider and relies on the hosting defence in regulation 19 of the E-Commerce Regulations 2002 and, for EU/EEA users, Article 6 of the DSA. We do not claim a single blanket hosting status for the Platform as a whole; instead, we reserve all statutory safe harbours, exemptions and defences, and their availability is assessed separately for each service function and each item of Content, on the relevant facts. Some of what we do — for example where we curate, select, organise, paywall, apply digital-rights management to, optimise, or actively communicate Content (including the curated and DRM-gated main stream, and the generation and external distribution of Share-Clips) — goes beyond the neutral, technical and passive storage of user information. Nothing in this policy admits that any defence is unavailable, or waives any defence — including for Content we curate, paywall, apply digital-rights management to, or deliver through access-gated technology. This policy reflects our commitment to act expeditiously on valid infringement notices in either case, consistent with our obligations under regulation 19 of the E-Commerce Regulations 2002 (to the extent it applies) and, for EU/EEA users, Articles 6 and 16 of the DSA.

3.2 No general monitoring obligation. We do not monitor all Content uploaded to the Platform for copyright compliance, and this policy does not create any general monitoring obligation on our part (consistent with Article 8 DSA). We rely on rightsholders and users to bring infringement to our attention through the notice procedures in sections 4 and 13.

3.3 Truthful disclosure of scanning. We operate a rule-based detection system in our community-chat feature. That system checks chat messages for specified content-rule violations; it does not perform copyright-fingerprinting of video or audio uploads. Video uploads and images are not automatically scanned for copyright infringement. We will not describe our systems in a way that is inaccurate or misleading about what proactive detection we actually carry out.

3.4 Our IP ethos. Steez exists so that art is protected and intellectual property is respected. Steelo Labs does not take ownership of creator music and does not hold a collective PRO/CMO licence unless expressly stated. Creators are fully responsible for the Content they post and warrant they own all rights to it (especially where it is monetised); we do not rely on how our fees are characterised as a defence to any rights-holder's claim. We may block, remove, hold, de-monetise, or require further clearance for Content where platform-level or rightsholder clearance may be required. We enforce exclusivity (access gating, DRM, and planned screen-capture blocking). When a genuine rights dispute arises, we back the rightful owner: we will share the directly-relevant data a disputer needs, redacting anything that would itself infringe another person's rights.

3.5 Active features — assessed on their own facts. Some Platform activity is carried out by, or at the direction of, the Platform and is not purely passive hosting. This includes the curation, paywalling and DRM-gating of the main content stream, and the generation and external distribution of Share-Clips. As set out in clause 3.1, we reserve all statutory safe harbours, exemptions and defences and assess their availability function-by-function and item-by-item; the fact that we curate, paywall, apply DRM to, or distribute Content is not an admission that any defence is unavailable for that activity. The creator licence grant in our Creator Terms & Earnings Agreement expressly covers clip generation and external distribution. See section 10 for further detail.

3.6 OSA and DSA obligations. As a user-to-user service regulated under the Online Safety Act 2023 (and, for EU/EEA users, the DSA), we operate user-reporting and notice-and-action mechanisms for illegal and harmful content. Copyright notices are separate from (but may overlap with) OSA- and DSA-mandated reporting. Where Content is reported as both copyright-infringing and otherwise unlawful, we will assess both routes.

4. Copyright Infringement Notices: How to Report

What this section says

To report copyright infringement, send us a written notice containing the information listed in 4.3. A materially incomplete notice may not qualify for our standard notice process, but we may still act where the information supplied gives us sufficient knowledge or awareness of apparently unlawful content, and we do not impose a routine delay before acting on an obvious infringement. We do not charge a fee to receive notices. EU/EEA users may also use the DSA notice-and-action route in section 13. US rightsholders should note the DMCA-specific requirements in section 14.

4.1 If you believe that Content on the Platform infringes your copyright (or the copyright of someone you are authorised to act for), you may submit a Notice to us using the contact details in section 16.

4.2 How to submit. Until a dedicated web form is available, submit your Notice by email to legal@steez.space.

4.3 Required information. A valid Notice must include all of the following:

(a) Your identity: your full legal name, postal address, email address, and telephone number. If you are acting on behalf of a rightsholder, state your authority to act (e.g., "I am the rightsholder's legal representative" or "I am an authorised agent of [rightsholder name]"). A collecting society or other PRO acting for its members should identify itself and the catalogue or membership it asserts rights over.

(b) The copyright work: a description of the copyright work you claim has been infringed. If multiple works are covered by a single Notice, provide a list. Where possible, provide a title, registration number, or other identifying details.

(c) The infringing Content: enough information to allow us to locate the Content on the Platform — ideally, the URL of the specific page, post, or stream; the Creator's username; and a description of where within any longer work the infringing material appears.

(d) Your ownership or authority statement: a statement that you are the owner of the copyright in the work(s) identified, or that you are authorised to act on the owner's behalf.

(e) Good-faith belief statement: a statement that you have a good-faith belief that the use of the material in the manner complained of is not authorised by the copyright owner, its agent, or applicable law.

(f) Accuracy statement: a statement that the information in the Notice is accurate.

(g) Signature (or electronic equivalent): a physical or electronic signature, or a typed full name confirming you are making the Notice on the basis set out above.

4.4 We may contact you to request missing information, and a materially incomplete Notice may not qualify for our standard notice process; but we may still act on a Notice that is sufficiently informative to give us knowledge or awareness of apparently unlawful Content, even if it is not formally complete. Requesting missing information does not suspend any response timeline.

4.5 Submitting a false or fraudulent Notice may expose you to civil liability, including for damages to the Uploader and to Steelo Labs, and to criminal liability where applicable. We reserve the right to share the contents of a Notice with the Uploader and, where required, with courts or regulatory authorities, in accordance with clause 3.4 (we redact anything that would itself infringe another person's rights) and our Privacy Policy.

4.6 Where a Notice relates to a licence dispute — that is, where you do not deny the Uploader has some right to the underlying work but contest the scope of that right — please make this clear. We may treat such cases differently from clear-cut infringement.

5. What Happens After We Receive a Copyright Notice

What this section says

We will review your notice and aim to action complete notices within 5 working days. If the notice is valid, we will remove or disable the content, notify the Uploader, and (for EU/EEA users) issue a Statement of Reasons. Where the Content was monetised — including through a first-hand Steez key, a subscription, or a content collection — we may also claw back revenue. There is no guarantee of any particular outcome — we exercise judgment.

5.1 Acknowledgement. We will acknowledge receipt of a Notice by email (to the address provided) as soon as reasonably practicable and in any event within two working days. Where the DSA applies, this acknowledgement is the confirmation required by Article 16(4).

5.2 Review. We will review the Notice to check that it is complete, that the Content is identifiable, and that the claim is not obviously without merit on its face. We may ask for clarification. Decisions are taken in a timely, diligent, non-arbitrary and objective manner.

5.3 Expeditious action. Where we determine that a Notice is valid and the Content appears to infringe the identified copyright, we will remove or disable access to that Content expeditiously and in any event within a reasonable period following receipt of a complete Notice. Our target is to action complete Notices within 5 working days.

5.4 Notification to Uploader and Statement of Reasons. On Takedown, we will notify the Uploader that their Content has been removed or disabled and the reason for the removal, and we will give the Uploader information about the Counter-Notice procedure in section 6. Where the same Content may also fall within a separate ground under our AUP — for example the §8.1 hard-ban on label-owned masters and unlicensed third-party recordings — a Counter-Notice is still accepted and processed under section 6 and can lead to reinstatement of the copyright Takedown; any decision to keep the Content unavailable on that separate ground is taken, and reasoned, in its own right under clause 6.8 and communicated to the Uploader. Where the Uploader is in the EU/EEA, or the restriction otherwise falls within the DSA, we will also provide a Statement of Reasons in accordance with section 13. We will not disclose the Claimant's personal contact details to the Uploader without the Claimant's consent, except where required by law, by a court or competent authority, or where lawful, necessary and proportionate to operate a fair counter-notice process. For example, for a US DMCA counter-notification, we may pass the Counter-Notice, including the Uploader's contact details, to the Claimant as required by 17 U.S.C. §512(g); for UK/EU processes, we disclose personal data only where the applicable law, authority, court order, or fair-process necessity justifies it.

5.5 Revenue clawback on monetised Content. Where infringing Content was monetised, we may reverse or withhold the associated revenue and recover it from the Creator's share on a cause-based basis only — that is, where there is evidence that the Creator breached these terms or the Creator Terms & Earnings Agreement (for example by uploading infringing or hard-banned Content), after notice to the Creator and an opportunity to challenge, consistent with clause 10.1 of the Creator Terms & Earnings Agreement. This applies across all monetisation surfaces, namely:

(a) First-hand Steez keys — sold by Steelo Labs at a fixed first-hand price of £30 GBP, with the creator paid a royalty of 80% calculated by reference to the net-of-VAT price;

(b) Creator subscriptions and content collections — sold by Steelo Labs, with the creator paid a royalty of 80% calculated by reference to the net-of-VAT price.

As between Steelo Labs and the Creator, recovery from the Creator for any resulting refund or reversal is cause-based only: we look to the Creator where there is evidence of breach, fraud, or a rights failure, and only after notice and an opportunity to challenge; absent that, Steelo Labs bears ordinary refunds and reversals as principal. This internal allocation never affects a consumer's statutory rights: where a Fan is entitled to a refund or other remedy under the UK Consumer Rights Act 2015, the Consumer Contracts Regulations 2013, or the equivalent mandatory consumer law of the Fan's own country, that remedy is honoured to the Fan immediately and unconditionally and is never delayed or denied by the question of creator responsibility.

5.6 Incomplete or contested Notices. Where a Notice is incomplete, we will request the missing information. Where a Notice is contested by the Uploader before we act, we will note the dispute and act on our own assessment of the complete picture.

5.7 Discretion. We retain discretion to decline to act on a Notice where: (a) the Notice is materially incomplete and we cannot reasonably identify the Content or the claimed work; (b) the alleged infringement is obviously covered by a defence (e.g., fair dealing under sections 29–31 CDPA, or an equivalent exception under the law applicable to the Claimant's right); (c) we have reason to believe the Notice is filed in bad faith or for an improper purpose; or (d) the Content has already been removed or the account terminated for other reasons.

5.8 No fee. We do not charge rightsholders any fee for processing Notices.

5.9 No guarantee of a particular outcome. Accepting a Counter-Notice (see section 6) does not automatically reinstate Content; whether the copyright Takedown is reversed follows the section 6 process, including the statutory window in clause 6.4. Where the same Content may also fall within a separate AUP ground (for example the §8.1 hard-ban), any decision to keep it unavailable on that ground is a distinct, separately reasoned decision under clause 6.8, communicated to the Uploader — it is never pre-announced as impossible.

6. Counter-Notices: Disputing a Takedown

What this section says

If your content was removed, you may file a counter-notice, which we accept and process. We will share a valid counter-notice with the Claimant; unless the Claimant tells us they have gone to court within the statutory window, the copyright takedown can be reversed. Where the same content may also fall within a separate AUP ground — such as the §8.1 hard-ban on label-owned masters and unlicensed third-party recordings — we do not treat reinstatement as impossible: any decision to keep it unavailable on that ground is taken and reasoned separately under clause 6.8 and communicated to you. EU/EEA users also have the internal-complaint and out-of-court dispute-settlement rights in section 13.

6.1 If you are the Uploader and your Content has been removed following a Notice, and you believe the removal was a mistake or that you have a right to post the Content, you may submit a Counter-Notice, which we will accept and process. Where the same Content may also engage a separate AUP ground, clause 6.8 explains how that ground is assessed and reasoned in its own right.

6.2 A Counter-Notice must include:

(a) your full legal name, email address, postal address, and telephone number;

(b) identification of the Content that was removed and the URL or description of where it appeared before removal;

(c) a declaration that the information in the Counter-Notice is accurate and made in good faith, and that you understand that making a false statement may give rise to civil liability under English law (and, where you submit from outside England and Wales, under any mandatory law of your own country that applies);

(d) a statement that you consent to the jurisdiction of the courts of England and Wales on a non-exclusive basis (or, if you are based outside the UK, that you will accept service of process from the original Claimant in connection with those courts), without prejudice to any right you have to bring or defend proceedings in the courts of your own country of habitual residence where mandatory law so provides;

(e) a physical or electronic signature (or typed full name).

6.3 Send your Counter-Notice to the contact address in section 16, clearly marked "COUNTER-NOTICE — COPYRIGHT".

6.4 Forwarding and put-back. On receipt of a valid Counter-Notice, we will forward it to the Claimant. We will inform the Claimant that, unless they notify us that they have commenced court proceedings to seek an order preventing reinstatement of the Content, we may reinstate the Content after 10 business days from the date of forwarding. Once that period expires without the Claimant filing suit, we will ordinarily reinstate the Content so far as the copyright Takedown is concerned, subject only to the limited carve-outs in clause 6.5 and to any separate, separately-reasoned AUP decision under clause 6.8.

6.5 Carve-outs to put-back. If we reinstate Content, we will notify both parties. Reinstatement of the copyright Takedown may be withheld where (a) we have independent grounds to believe the Content infringes, or (b) the account has been suspended for other reasons. Separately, where the Content also engages an AUP ground — for example it is a label-owned master or unlicensed third-party recording prohibited under section 9 and AUP §8.1, or it would otherwise violate our AUP or applicable law — any decision to keep it unavailable on that ground is taken under clause 6.8 as its own reasoned decision, communicated to the Uploader, rather than as an automatic bar. Clause 6.4 is read together with this clause.

6.6 Legal disputes. If the Claimant obtains a court order prohibiting reinstatement, we will comply. We will not repost Content that a court has ordered removed.

6.7 False counter-notices. Submitting a false Counter-Notice may expose you to civil and, where applicable, criminal liability.

6.8 Separate AUP grounds — assessed and reasoned in their own right. A Counter-Notice is accepted, processed, and — absent a court order, or the Claimant notifying us within the statutory window (clause 6.4) that they have filed suit — can lead to reinstatement of the Content so far as the copyright Takedown is concerned. This includes a US DMCA counter-notification under §512(g) (clause 14.6), which we always process on its statutory merits. Where the same Content also appears to fall within a separate ground under our AUP — in particular the §8.1 hard-ban on label-owned master recordings or unlicensed third-party recordings (and section 9) — any decision to keep the Content unavailable on that ground is a distinct decision, taken on its own facts under that ground, for which we give the Uploader a reasoned explanation and the appeal routes in section 7 and (for EU/EEA users) section 13. We do not pre-announce that reinstatement is impossible. A direct rightsholder licence may resolve the §8.1 ground; even then we may, by a reasoned decision, decline to host the Content as a matter of policy. Where a Takedown is confirmed as infringing, it counts as a repeat-infringement event under clause 7.2.

7. Repeat-Infringer Policy

What this section says

We will terminate or suspend the accounts of users who repeatedly infringe intellectual-property rights. This section explains how we assess "repeat infringement" and the consequences. Takedowns of hard-banned label masters count as strikes whether or not a counter-notice is filed.

7.1 Obligation. Steelo Labs maintains and enforces a policy providing for termination of user accounts in appropriate circumstances where users are repeat infringers. Maintaining such a policy is a condition of our eligibility for Stripe's platform programmes and a matter of good practice for the hosting-defence framework under regulation 19 of the E-Commerce Regulations 2002 (to the extent it applies — see clause 3.1), Article 6 DSA, and, where applicable, US §512(i).

7.2 What counts as infringement for this purpose. For the purposes of this section, an infringement event is recorded when:

(a) a valid Notice is received and results in a Takedown; or

(b) a Takedown is initiated by us on our own assessment (e.g., following a moderation review); or

(c) a court or arbitral tribunal issues an order finding or presuming infringement relating to Content uploaded by that user.

Withdrawn Notices (before action is taken) and Notices we decline (see clause 5.7) do not count. Contested Notices that are resolved in the Uploader's favour following a Counter-Notice process do not count — except that a Takedown of a label-owned master or unlicensed third-party recording hard-banned under AUP §8.1 and section 9 counts as an infringement event even where a counter-notice is filed, because the AUP §8.1 ground is assessed in its own right (clause 6.8) and, where that ground is made out, the Content remains unavailable on that separate basis.

7.3 Escalation ladder. We apply a graduated response:

7.4 Discretion and severity. The above table reflects default escalation steps. We may escalate more quickly — including to immediate termination — where:

(a) the infringement is egregious or large-scale;

(b) the user has demonstrated a clear intent to infringe (e.g., uploading the same removed content after a Takedown);

(c) the infringement involves commercial recordings or label-owned masters (see section 9 and AUP §8.1);

(d) the infringement is supported by credible item-specific rights evidence, a court or competent-authority order, or evidence of egregious scale or repeat conduct. A notice from a major rightsholder, PRO, collecting society, or law-enforcement authority may supply relevant evidence, but status alone does not replace the need to assess the item-specific facts.

7.5 Appeals. Termination under this section may be appealed through our Moderation, Complaints & Appeals Procedure. For EU/EEA users, the internal-complaint and out-of-court dispute-settlement routes in section 13 also apply. Where an appeal concerns Content held down under the AUP §8.1 hard-ban, that ground is considered on its own facts and we give a reasoned decision on it (clause 6.8); reinstatement is not ruled out in advance, but continued unavailability may follow where the §8.1 ground is made out.

7.6 Creator accounts and revenue clawback. Where a Creator account is terminated for repeat infringement, any outstanding payout balance — including amounts arising on first-hand sales, subscriptions, and content collections (clause 5.5) — will be reviewed before release. We retain revenue-clawback and set-off rights and will hold sums pending where we have claims, chargebacks, refunds, or potential liability arising from the infringing Content, as set out in clause 5.5 and the Creator Terms & Earnings Agreement. Nothing in this clause affects Stripe's own rights over the Creator's Express account, and nothing in it delays or denies a consumer's statutory remedy.

7.7 No circumvention. A Creator whose account is terminated may not re-register under a different name or through another account to circumvent this policy. This constitutes a further breach of the Terms of Service.

8. Takedown Log and Record-Keeping

What this section says

We keep a log of all notices received, actions taken, statements of reasons, and counter-notices. These records support our legal defences and regulatory obligations.

8.1 We maintain an internal log of:

(a) each Notice received (date, Claimant identity, Content identified, claimed work);

(b) our response to each Notice (action taken, date of action, reasons for declining to act where applicable);

(c) each Counter-Notice received and our response (including, where applicable, any separate AUP §8.1 decision under clause 6.8);

(d) each Statement of Reasons issued under the DSA (see section 13);

(e) reinstatements; and

(f) repeat-infringer account actions under section 7.

8.2 Log entries are retained for the longer of (a) 6 years from the action date; or (b) resolution of any related legal proceedings. This aligns with the 6-year retention of moderation and enforcement records described in our Privacy Policy.

8.3 Log records may be disclosed to Ofcom, the European Commission, EU Digital Services Coordinators, courts, or other regulatory or law-enforcement authorities as required or permitted by law. They may also be disclosed to parties in legal proceedings to which we are a party. We will handle all personal data in log records in accordance with our Privacy Policy and the UK GDPR (and, for EU/EEA personal data, the EU GDPR).

8.4 Log records are not published publicly. We may publish anonymised aggregate statistics (e.g., total Notices received per period) at our discretion. While the Article 19 micro/small-enterprise exemption applies to us, we are not required to submit statements of reasons to the European Commission's DSA Transparency Database under Article 24(5); we may do so voluntarily, and the duty becomes mandatory if that exemption ceases or on designation as a Very Large Online Platform.

9. Music-Specific Guidance

What this section says

Music copyright on Steez involves multiple overlapping rights. Steelo Labs does not take ownership of creator music and does not hold a collective PRO/CMO licence unless expressly stated. Creators must own or control all rights to the music they upload and are fully liable for it. We may block, remove, hold, de-monetise, or require further clearance where platform-level or rightsholder clearance may be required. Label-owned masters and unlicensed third-party recordings are hard-prohibited (AUP §8.1). Cover versions are prohibited at launch.

9.1 The music-rights landscape. Music typically involves two separate and independently owned layers of copyright:

(a) The composition (the melody and lyrics, owned by the songwriter and/or publisher, the performing right in which is often managed by a PRO such as PRS for Music or, internationally, ASCAP, BMI, GEMA, SACEM and equivalents); and

(b) The sound recording (the recorded performance of the composition, owned by the artist or, for commercially released tracks, by the record label).

A creator who performs their own original music may own the sound recording in their performance. They remain responsible for ensuring they hold or control every right needed to post and monetise that music on the Platform, including any composition right managed on their behalf by a PRO of which they are a member.

9.2 No platform music licence — warranties-only posture. Steelo Labs does not take ownership of creator music and does not hold a collective PRO/CMO licence unless expressly stated. We do not rely on any collective PRO/CMO licence (PRS for Music, MCPS, PPL, ASCAP, BMI, SESAC, GEMA, SACEM or any other) covering on-demand streaming of musical works on the Platform unless expressly stated. We do not rely on how our fees are characterised as a defence to any rights-holder's claim. Responsibility for clearing all music rights rests entirely with the uploading Creator, who is fully liable for the Content they post (see clause 9.3). We host that Content (to the extent we act as host — clause 3.1), and we retain the right to remove it on notice and to claw back any associated revenue under clauses 5.5 and 7.6.

9.3 What creators must own. Our Creator Terms & Earnings Agreement requires every Creator to warrant, for all music content they upload, and to indemnify Steelo Labs accordingly, that:

(a) they own or control all composition rights (including any samples and co-writer shares);

(b) they own or control all sound-recording rights in their performance; and

(c) they are not subject to any conflicting label exclusivity, publisher exclusivity, or PRO-membership restriction that would prevent them from posting or monetising the Content on the Platform.

Breach of these warranties is grounds for Takedown and revenue clawback, and may result in account termination under section 7 and/or further enforcement action and indemnity recovery under the Creator Terms & Earnings Agreement.

9.4 Label-owned masters and unlicensed recordings: hard-prohibited (AUP §8.1). Commercial recordings where the sound recording is owned by a record label ("label masters"), and any other third-party recording the Creator is not authorised to use, are hard-prohibited on the Platform under AUP §8.1. We hold no licence that would cover on-demand streaming of label-owned recordings on a platform of our type. Uploading a label master or an unlicensed third-party recording is a material breach of the AUP and of the Creator Terms & Earnings Agreement. We will remove such Content expeditiously on notice (and, where we become aware of it, on our own assessment). A copyright counter-notice under section 6 is still accepted and processed for such Content (clause 6.8); but the AUP §8.1 hard-ban is a separate ground, and where that ground is made out the Content may remain unavailable on that basis by a reasoned decision communicated to the Uploader. We will treat a confirmed Takedown as a repeat-infringement event under section 7. Any associated first-hand revenue is subject to clawback under clause 5.5 on the cause-based basis set out there.

9.5 Covers and other third-party compositions — prohibited at launch. A cover version reproduces the underlying composition; a Creator's own performance of a cover does not clear the songwriter's composition right. Cover versions are prohibited on the Platform at launch. There is no "permitted with clearance" route for covers at this stage: Content using a third-party composition (including a cover, even one the Creator has independently licensed) is not permitted while this launch prohibition is in force. This aligns with the corresponding prohibitions in our Terms of Service, AUP §8.3, and Creator Terms & Earnings Agreement. Rightsholders wishing to report an unlicensed cover or other third-party composition should follow section 4.

9.6 Music notices from PROs and collecting societies. PROs and collecting societies (such as PRS for Music, MCPS, PPL, ASCAP, BMI, SESAC, GEMA, SACEM and their equivalents) are recognised as authorised representatives of their members for the purpose of submitting Notices under section 4. This recognition does not imply, and must not be read as, any licence purchased from or held with any such organisation. Notices from a PRO must still meet the requirements of clause 4.3 but need not identify an individual rightsholder where the PRO asserts an entitlement to act on behalf of its membership catalogue. Where a PRO contacts us asserting a "please-pay" or licensing position rather than reporting specific infringing Content, we will engage with it through our rights-holder claim-handling process; this does not constitute an admission of liability or the purchase of any licence.

10. Share-Clip Distribution

What this section says

Non-exclusive content can be shared externally as a short watermarked clip. Exclusive content cannot be shared outside the app. We have created this feature, which means it is not purely passive hosting — it is covered by a separate licence grant in our creator terms. Once a clip has been shared onto a third-party platform, we can request its removal through that platform's own process, but we cannot unilaterally pull it down ourselves.

10.1 The Platform includes a feature that allows Fans and Creators to generate a short, watermarked clip of non-Exclusive Content ("Share-Clip") for external distribution on third-party social-media platforms and messaging services. Exclusive Content is hard-blocked from Share-Clip generation and cannot be shared outside the Platform.

10.2 Share-Clips are watermarked with Steez Platform branding. The original source video asset is not distributed via Share-Clips.

10.3 Creator licence grant. The Creator Terms & Earnings Agreement requires Creators to grant Steelo Labs a non-exclusive, royalty-free, sublicensable licence to generate Share-Clips and distribute them to third-party platforms as part of the Platform's sharing feature, and provides for a per-creator toggle controlling external sharing.

10.4 Active-distribution disclosure. Steelo Labs acknowledges that generating and distributing Share-Clips is not purely passive hosting. As stated in clause 3.1, we reserve all statutory safe harbours, exemptions and defences and assess their availability separately for each function and item; generating and distributing a Share-Clip is not an admission that the reg-19 / Article 6 hosting defence is unavailable for that artifact. Steelo Labs takes responsibility for ensuring it has appropriate rights from Creators to carry out Share-Clip generation and distribution, and will act on valid Notices relating to Share-Clip content in the manner set out in clauses 10.5 and 10.7.

10.5 Music in Share-Clips. Share-Clips inherit the music-right status of the underlying Content. A Share-Clip generated from Content containing prohibited label-owned masters or unlicensed compositions is itself infringing. Rightsholders may report infringing Share-Clips under section 4.

10.6 Duration. Share-Clips are short excerpts.

10.7 What we can do once a clip is on a third-party platform. Where a Share-Clip has already been distributed onto a third-party platform or messaging service, that copy sits on infrastructure we do not control. On a valid Notice we will (a) stop further generation of the relevant Share-Clip and disable its in-Platform sharing route; (b) where the clip remains accessible from the Platform, remove or disable it; and (c) request removal of the externally distributed copy via the third-party platform's own notice-and-takedown or content-removal process and cooperate with the rightsholder's own request to that platform. We cannot guarantee, and do not promise, that we can unilaterally or remotely delete a Share-Clip that a third-party platform is hosting — removal of that copy ultimately depends on the third-party platform's process.

11. Trademark and Impersonation Reports

What this section says

We deal with trademark infringement and impersonation through a similar notice-and-action process to copyright. This section explains how to report.

11.1 If you believe that Content or a user account on the Platform infringes your registered or unregistered trademark rights, or is impersonating you or another real person or brand, you may report it to us.

11.2 Reporting. Reports should be sent to us at the contact details in section 16, clearly marked "TRADEMARK REPORT" or "IMPERSONATION REPORT" as appropriate.

11.3 Required information for trademark reports. Your report should include:

(a) your full legal name and contact details;

(b) your trademark registration number(s) (if registered) or, for unregistered marks, a description of the rights you claim, the territory, and evidence of use;

(c) a description of the Content or account that you believe infringes or impersonates;

(d) a URL or other identifier locating the Content or account;

(e) an explanation of how the use constitutes infringement or impersonation; and

(f) a statement that the information provided is accurate and that you are the rights owner or authorised to act.

11.4 Impersonation. Impersonating a real person (including a creator, public figure, or brand) is a breach of our AUP. Verified impersonation reports may result in Takedown of the Content and/or suspension of the account. Where an account is clearly impersonating another user on our Platform, the impersonated user may also report through the Platform's in-app reporting function.

11.5 Username disputes. Disputes over usernames alleged to constitute trademark squatting or bad-faith registration of a brand name will be assessed on the specific facts. We do not guarantee any particular outcome and will act proportionately.

11.6 This policy is not a dispute-resolution service. We assess trademark and impersonation reports in good faith and in our reasonable discretion. We are not a substitute for court proceedings or specialist intellectual-property dispute mechanisms.

12. Defamation and Other Non-Copyright Complaints

What this section says

Complaints about defamatory content follow a different process under the Defamation Act 2013. This section routes you to the right mechanism.

12.1 Complaints about allegedly defamatory Content — that is, Content that you claim is false and damages your reputation — are governed by a different legal framework from copyright complaints. The relevant procedure is the Defamation (Operators of Websites) Regulations 2013 (SI 2013/3028), which sets out how operators of websites (such as Steelo Labs) can maintain the s.5 Defamation Act 2013 website-operator defence.

12.2 If you wish to make a complaint about allegedly defamatory Content, you must follow the formal process under SI 2013/3028. The Regulations set time limits expressed in 48-hour periods. Those periods are not continuous clock-time: under the Regulations, in calculating a period of hours, time that falls on a Saturday, Sunday, Good Friday, Christmas Day, or a bank holiday in England and Wales is excluded. The clock starts when we receive a valid complaint (including one received out of hours), and we calculate each deadline in accordance with that rule. We operate an always-on intake that timestamps complaints on receipt and escalates them so that the statutory periods are met. Valid complaints must meet the requirements of the Regulations; defective complaints will be returned, within the period the Regulations allow, with a statement of the defects.

12.3 Until a dedicated intake form is available, send defamation and other non-copyright complaints by email to legal@steez.space.

12.4 On receipt of a valid s.5 complaint, we will follow the procedure required by the Regulations: we will attempt to contact the poster and provide them with the opportunity to respond. If the poster is unidentifiable or unresponsive within the required period, or if they consent to removal, we will take appropriate action. Our Moderation, Complaints & Appeals Procedure sets out the appeals route.

12.5 Other non-copyright IP or content complaints. If your complaint relates to a right not addressed by this policy — such as database rights, performance rights, moral rights, design rights, passing-off, or other unlawful content — please contact us using the details in section 16 with a clear description of the right you are asserting and the relevant Content. We will consider each complaint on its merits.

12.6 OSA / DSA reporting tools. Where Content is illegal (not merely a civil wrong) and you wish to report it under the OSA- or DSA-mandated reporting mechanism, please use the in-app or in-website reporting function rather than this policy. EU/EEA users may also use the notice-and-action route in section 13. Copyright and trademark infringement are primarily civil wrongs; this policy is designed for that category.

13. EU Digital Services Act: Notice-and-Action and Statement of Reasons

What this section says

If and when Steez's paid services are offered in the EU/EEA (not at launch — see Terms of Service §2.1), this section gives EU/EEA users the additional rights the Digital Services Act requires: an electronic notice-and-action mechanism, a written statement of reasons for any restriction, an internal complaint route, out-of-court dispute settlement, and a point of contact and legal representative in the EU.

13.1 Notice-and-action (Article 16 DSA). EU/EEA users and rightsholders may submit a notice of allegedly illegal Content (including IP-infringing Content) through the electronic notice-and-action mechanism. A valid DSA notice should include: (a) a sufficiently substantiated explanation of why the Content is alleged to be illegal; (b) a clear indication of the exact electronic location of the Content (for example the URL); (c) the name and email address of the person or entity submitting the notice (except for notices concerning certain child-sexual-abuse offences); and (d) a statement of the submitter's good-faith belief that the information is accurate and complete. The section 4 copyright Notice and the section 11 trademark report both satisfy these requirements and may be used by EU/EEA Claimants.

13.2 Confirmation and diligence. We will send the submitter a confirmation of receipt without undue delay and will notify them of our decision in respect of the Content, with information about redress. We process all notices in a timely, diligent, non-arbitrary, and objective manner.

13.3 Statement of Reasons (Article 17 DSA). Where we impose any restriction on Content or an account affecting a recipient in the EU/EEA — including removal, disabling, or restricting visibility, and including any restriction on monetisation, monetary terms, or payout — we will provide that recipient with a clear and specific Statement of Reasons. It will set out, as applicable: the restriction imposed and its territorial and temporal scope; the facts and circumstances relied on (including whether the decision followed a notice or our own-initiative assessment, and whether automated means were used); the legal or contractual ground relied on; and the redress options available, including the internal-complaint mechanism, out-of-court dispute settlement, and judicial remedy. Where the restriction rests on the AUP §8.1 hard-ban, the Statement of Reasons will say so, will give the reasons for keeping the Content unavailable on that ground, and will confirm that a copyright counter-notice is still processed and that the internal-complaint and out-of-court routes remain open. Article 24(5) is the DSA transparency-database provision for statements of reasons. While the Article 19 micro/small-enterprise exemption applies to us, Article 24(5) is not mandatory for us (unlike Article 24(3)); we may submit Statements of Reasons to the Commission database voluntarily, and we will do so if and when the duty becomes mandatory.

13.4 Internal complaint-handling (Article 20 DSA). As a micro/small enterprise we are currently exempt from DSA Articles 20–21 under Article 19; we offer the following voluntarily while that exemption applies, and they become mandatory if it ceases or on VLOP designation. 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. A recipient affected by a restriction decision may lodge a complaint through our internal complaint-handling system (our Moderation, Complaints & Appeals Procedure) for at least six months after the decision. We will handle complaints in a timely, non-discriminatory, diligent, and non-arbitrary manner, and will reverse a decision where the complaint shows the Content is not illegal or incompatible with our terms.

13.5 Out-of-court dispute settlement (Article 21 DSA). Recipients in the EU/EEA may also refer a dispute to a certified out-of-court dispute-settlement body. Selecting such a body does not deprive the recipient of access to the courts.

13.6 Point of contact and legal representative (Articles 11, 12, 13 DSA). We will designate a single electronic point of contact for EU/EEA authorities and for recipients of the service, and will appoint a legal representative established in a Member State of the EU for the purposes of the DSA. For data-protection matters, an EU representative under Article 27 EU GDPR is in the process of being appointed; until appointed, EU/EEA users can contact us directly at privacy@steez.space. Contact details will be inserted in section 16 once these appointments are confirmed.

13.7 No general monitoring. Nothing in this section imposes a general monitoring or active fact-finding obligation on Steelo Labs (Article 8 DSA).

14. US DMCA Notices and International Notices

What this section says

Steez's paid services are offered in the UK and US at launch. Our US Copyright Office designated-agent registration will be completed before this policy is offered to US users; US rightsholders may then use the DMCA-equivalent notice route. This section also covers notices from anywhere else and summarises US users' privacy rights.

14.1 US DMCA notices. Because the Platform is available to US-based users, US rightsholders who wish to submit a notice in compliance with the DMCA may use the procedure in section 4. A US DMCA notice must also include the statutory statements required by 17 U.S.C. § 512(c)(3): (i) a statement that the complaining party has a good-faith belief that the use of the material is not authorised by the copyright owner, its agent, or the law; and (ii) a statement that the information in the notice is accurate, and — under penalty of perjury — that the complaining party is authorised to act on behalf of the owner of the exclusive right allegedly infringed.

14.2 DMCA designated agent. US safe-harbour protection under 17 U.S.C. § 512(c) is available only to a service provider that has designated an agent with the US Copyright Office under 17 U.S.C. § 512(c)(2). Steelo Labs will designate an agent with the US Copyright Office for the Steez platform before Steez is offered to US users; the registered agent's name and contact details will be set out in section 16 once registration completes, and notices and counter-notices concerning US-accessible Content may then be sent to that agent.

14.3 Repeat infringers (§512(i)). Pursuant to 17 U.S.C. § 512(i), it is the policy of Steelo Labs to terminate the accounts of users who are determined to be repeat infringers in appropriate circumstances. See section 7.

14.4 US privacy rights. US-based users may have additional rights over their personal data under state laws such as the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) and equivalent state statutes; these are described in our Privacy Policy.

14.5 International notices generally. We receive and assess Notices from rightsholders anywhere in the world. The requirements of section 4 apply regardless of the Claimant's location. We will assess the strength of the claimed right under the law of the country where the right is registered or subsists, while our handling of the Notice and any dispute about our handling is governed by English law on a non-exclusive basis, subject to the mandatory-rights saver in clause 1.4.

14.6 US counter-notification (17 U.S.C. § 512(g)). A US-based Uploader whose Content was removed following a DMCA notice may submit a DMCA counter-notification under § 512(g). This is separate from the general counter-notice in section 6, and uses the statutory US requirements rather than the English-law consents in clause 6.2. A § 512(g) counter-notification must contain: (a) your physical or electronic signature; (b) identification of the removed material and its prior location; (c) a statement under penalty of perjury that you have a good-faith belief the material was removed as a result of mistake or misidentification; (d) your name, address, and telephone number; (e) a statement that you consent to the jurisdiction of the Federal District Court for the judicial district in which your address is located (or, if outside the US, any judicial district in which Steelo Labs may be found); and (f) a statement that you will accept service of process from the person who submitted the original notice or their agent. On receipt of a compliant § 512(g) counter-notification, we will promptly forward it to the person who submitted the original notice. Unless that complainant notifies us that it has filed an action seeking a court order to restrain the infringing activity, we may restore or cease disabling access to the Content no fewer than 10 and no more than 14 US business days after we forward the valid counter-notification, as 17 U.S.C. § 512(g) permits. Where the same Content also engages the AUP §8.1 hard-ban, that ground is assessed separately under clause 6.8: the § 512(g) counter-notification is still accepted and processed on its statutory merits, and if we keep the Content unavailable it is on the separate, separately-reasoned AUP ground communicated to the Uploader — not by treating the statutory route as unavailable — and we do not rely on § 512(g) safe-harbour protection for that separate non-restoration decision itself. Nothing in section 6 or clause 6.8 removes a US Uploader's statutory right to submit a § 512(g) counter-notification, and a contractual AUP ground does not make the statutory route unavailable.

14.7 Notices from collecting societies / PROs — three types. Where a notice comes from a PRO or collecting society, we distinguish three different kinds of communication and handle each differently: (a) an item-specific infringement notice (a claim that a specific item of Content infringes a specific work) — handled under sections 4–5; (b) a repertoire or membership assertion (a statement that the PRO administers rights in a body of works, or that a creator is a member) — treated as information that may trigger a hold or clearance request, not as an item-specific takedown; and (c) a platform-licensing demand (a request that Steelo Labs take a blanket or platform licence) — treated as a commercial/licensing matter for our legal team, not as a takedown notice. Classifying a communication as (b) or (c) does not by itself require removal of specific Content, but may lead us to block, hold, or de-monetise affected Content pending clearance (clause 3.4).

15. Liability, Good Faith and Your Statutory Rights

15.1 We act in good faith when assessing Notices, Counter-Notices, and DSA notices. Where we act on a Notice that turns out to be incorrect or invalid, our liability to the Uploader is limited to taking appropriate steps to reinstate the Content and correct our records, except where we acted negligently, irrationally, or in breach of contract. We exclude liability for loss or damage arising from our good-faith reliance on a Notice that was inaccurate or fraudulent, save to the extent our act was negligent or in breach of our obligations under applicable law.

15.2 Where a Claimant submits a Notice that is false, fraudulent, or filed for the purpose of suppressing lawful speech (sometimes called an "abusive takedown"), the Claimant bears civil and, where applicable, criminal liability. We reserve the right to take action, including restoring Content and seeking indemnification or damages, where we determine that a Notice was filed in bad faith.

15.3 Nothing in this policy excludes or limits Steelo Labs' liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any other liability that cannot lawfully be excluded.

15.4 Nothing in this policy excludes or limits the statutory rights of consumers, or any mandatory rights you have under the law of your country of habitual residence that cannot lawfully be excluded. Where those mandatory rights conflict with this policy, they prevail to the extent of the conflict (see clause 1.4). In particular, the internal cause-based cost allocation in clause 5.5 never delays or denies a consumer's statutory remedy. A Steez key is not a financial asset, security, investment, e-money, stored value, deposit, trust asset, ownership interest, or share of creator/platform revenue; it is personal, non-transferable, and non-resellable, and carries no guaranteed or realisable monetary value.

16. Contact Details

For copyright, trademark, and impersonation notices and counter-notices, and for EU/EEA DSA notices:

Email: legal@steez.space

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

For defamation complaints (s.5 Defamation Act 2013 / SI 2013/3028) and general legal enquiries:

Email: legal@steez.space

For privacy and data-protection matters (including EU GDPR Art 27 representative):

Email: privacy@steez.space EU GDPR Article 27 representative: in the process of being appointed — until appointed, contact privacy@steez.space

For general support:

Email: support@steez.space

EU DSA point of contact / legal representative: in the process of being appointed — until appointed, contact legal@steez.space

US DMCA designated agent (clause 14.2): «to be inserted before US launch»

Annex A — Summary Table of Notice Requirements

Annex B — Key Legislation and Policy Cross-References