EU Digital Services Act Information

1. About This Page

1.1 This page provides the information that GLOBAL ENTERPRISE CLOUD SYSTEMS ("GECS"), trading as AdultSense, makes available under Regulation (EU) 2022/2065 (the Digital Services Act, "DSA"). It applies to recipients of our services in the European Union and supplements our Terms of Service, Abuse Reporting Policy and Copyright Policy.

1.2 AdultSense is an online advertising marketplace and ad-serving intermediary. It connects Advertisers with independent third-party Publishers. GECS stores advertising creatives, ad code and marketplace listings at the request of its clients, and serves advertising on Publisher Websites that it does not own or operate.

2. Single Point of Contact

2.1 Our single point of contact for Member State authorities, the European Commission and the European Board for Digital Services (Art. 11), and for recipients of the service (Art. 12), is: Show email. Please use the subject "DSA – Authority" or "DSA – User" as appropriate.

2.2 Communications may be in English. Recipients may communicate with us by email; we do not rely solely on automated tools to respond.

2.3 Legal representative in the EU (Art. 13): where applicable law requires GECS to appoint a representative, their details will be provided on request via Show email.

3. Notice and Action (Art. 16)

3.1 Anyone may notify us of content they consider illegal by email to Show email with subject "DSA notice". A notice should contain: (a) a sufficiently substantiated explanation of why the content is considered illegal; (b) a clear indication of its exact electronic location, such as URLs or the ad creative; (c) the name and email of the notifier, except for notices concerning child sexual abuse offences; and (d) a statement confirming the notifier's good-faith belief that the information is accurate and complete.

3.2 We 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. Where we use automated means in processing, we say so.

4. Statement of Reasons (Art. 17)

4.1 When we remove or disable content, demote or restrict its visibility, suspend or restrict payment-related or monetary entitlements, or suspend or terminate an account, we provide the affected user with a clear and specific statement of reasons, including: the restriction imposed and its scope and duration; the facts and circumstances relied upon; whether automated means were used; the legal ground or contractual provision relied upon; and the redress available.

5. Reporting Criminal Offences (Art. 18)

5.1 Where we become aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of persons has taken place, is taking place or is likely to take place, we promptly inform the law enforcement or judicial authorities of the Member State concerned. Child sexual abuse material is reported to NCMEC and/or the IWF and relevant authorities.

6. Internal Complaint Handling (Art. 20)

6.1 Users and notifiers may lodge a complaint against our decisions, free of charge, for six (6) months after being informed of the decision, by emailing Show email with the subject "DSA complaint". Complaints are handled in a timely, non-discriminatory, diligent and non-arbitrary manner under the supervision of appropriately qualified staff, not solely by automated means. We reverse decisions where the complaint shows they were unfounded.

7. Out-of-Court Dispute Settlement (Art. 21)

7.1 Users in the EU may select any out-of-court dispute settlement body certified by a Digital Services Coordinator to resolve disputes relating to our decisions, including complaints not resolved by our internal system. We will engage in good faith with the selected body. This does not affect your right to bring proceedings before a court.

8. Trusted Flaggers (Art. 22)

8.1 Notices submitted by trusted flaggers awarded that status by a Digital Services Coordinator, within their designated area of expertise, are given priority and processed without undue delay. Trusted flaggers should identify themselves in the subject line: "DSA notice – Trusted flagger".

9. Measures Against Misuse (Art. 23)

9.1 After a prior warning, we suspend for a reasonable period the provision of our services to users who frequently provide manifestly illegal content, and suspend for a reasonable period the processing of notices and complaints from persons who frequently submit manifestly unfounded notices or complaints. We assess misuse case by case, considering the number, gravity and intent of the items concerned.

10. Advertising Transparency (Art. 26)

10.1 Advertisements served through our ad server are designed to be identifiable as advertising. Clients can identify, for each advertisement, the Advertiser on whose behalf it is presented and, where different, who paid for it. Advertising on AdultSense is sold as fixed positions per calendar month and is not targeted using profiling of individual users based on special categories of personal data. We do not present advertisements based on profiling where we know with reasonable certainty that the recipient is a minor.

10.2 Users may obtain information about the main parameters used to determine why an advertisement was shown (typically the Publisher Website and position purchased, country and device) by contacting Show email with the subject "Ad transparency".

11. Terms and Conditions (Art. 14)

11.1 Information on restrictions we impose, including content moderation policies, procedures, measures, tools and our internal complaint system, is set out in our Terms of Service, Advertiser Guidelines, Publisher Guidelines, Acceptable Use Policy and Traffic Quality Policy. Content moderation combines automated screening of creatives and traffic with human review.

12. Transparency Reporting (Art. 15 and 24)

12.1 GECS publishes information as required by applicable law, including, to the extent required for our category of service, information about orders from authorities, notices and actions taken, own-initiative moderation, use of automated tools, complaints and out-of-court disputes. Requests for this information may be sent to Show email.

12.2 Average monthly active recipients in the EU (Art. 24(2)): GECS is not a very large online platform and has fewer than 45 million average monthly active recipients in the Union. GECS publishes information about this figure as required by applicable law.

13. Orders from Authorities (Art. 9 and 10)

13.1 Orders to act against illegal content or to provide information should be sent to the single point of contact. We inform the issuing authority of the effect given to the order without undue delay, and inform the affected user where required.