ReloSale Moderation, Complaints, Restrictions and Appeals Policy

This ReloSale Moderation, Complaints, Restrictions and Appeals Policy (hereinafter referred to as the Moderation Policy) sets out the procedures and principles for reviewing content, accounts and user activities, handling complaints, applying restrictive measures, and appealing Platform decisions.

The Moderation Policy applies to all Platform users, all posted content, all accounts, all communications, and all actions performed in connection with the use of ReloSale.

By using the Platform, the user agrees that the content they post, their account and their activities may be subject to manual and automated review in accordance with this Policy, the Terms of Use and other Platform documents.

Moderation on the Platform is carried out for the following purposes:

• identifying violations of the Terms of Use, Platform rules and applicable legislation;
• preventing fraud, spam, abuse and manipulation;
• removing prohibited, illegal, dangerous or harmful content;
• ensuring the quality of search results, the catalogue and recommendations;
• protecting users from misleading content, false offers and fraudulent schemes;
• protecting intellectual property, personal data and the right to privacy;
• complying with applicable legislation, regulatory orders and court decisions;
• maintaining a safe, fair and comfortable environment for all Platform participants.

The following may be subject to moderation, including but not limited to:

• listings — both before publication (at the review stage) and after publication;
• titles, descriptions, prices, categories, attributes and other listing parameters;
• photographs, videos, documents and other media files attached to listings or profiles;
• user profiles, including name, photo, description, contact details and statuses;
• reviews, comments, ratings and other forms of user feedback;
• correspondence between users — to the extent permitted and for the purposes set out in this Policy and applicable legislation;
• advertising placements, promoted listings and other paid tools;
• user activity on the Platform, including behavioural patterns, technical signals and activity history.

4.1. Pre-publication Moderation

Review of content before its publication on the Platform. Listings, photographs, documents and other materials may undergo review before they become available to other users. The timeframe for pre-publication moderation depends on the category, region, content type and current workload.

4.2. Post-publication Moderation

Review of content after its publication — based on technical signals, user complaints, external notifications, changes in rules or as part of regular scheduled reviews.

4.3. Automated Moderation

Use of technical systems, algorithms, filters and models to detect duplicates, fraudulent listings, spam, prohibited content, suspicious activity, category rule violations and other anomalies. Automated moderation may be applied independently or in combination with manual review.

4.4. Manual Moderation

Review of content and user activity by Platform specialists. Applied in complex, ambiguous or sensitive cases, when handling complaints and appeals, and in situations where automated tools are insufficient for decision-making.

4.5. Reactive Moderation

Moderation initiated by user complaints, rights-holder notices, notifications from government authorities, partners or other third parties.

Review and intervention may be carried out on the following grounds:

• violation of the Terms of Use, Platform rules, individual category rules or other ReloSale documents;
• posting misleading, inaccurate or incomplete information;
• publication of prohibited, illegal, dangerous or offensive content;
• signs of fraud, phishing, social engineering, document forgery or other bad-faith actions;
• complaints from users, rights holders, partners or government authorities;
• signs of multi-accounting, circumvention of restrictions, rating manipulation, artificial boosting or abuse of Platform features;
• risk of harm to users, third parties, the Platform or its reputation;
• failure to provide requested documents, explanations or confirmations within the prescribed timeframe.

Depending on the nature and severity of the violation, the Platform may apply one or more of the following measures:

• rejection of a listing before publication, with or without stating the reason;
• hiding a listing from search results, the catalogue or recommendations;
• removal of a listing, individual listing elements (photos, descriptions, prices, contacts) or an entire group of listings;
• temporary de-publication of a listing for the duration of a review;
• limiting impressions, promotion, communications or access to individual features;
• disabling paid services, advertising tools or bonus programmes;
• issuing warnings, labels, statuses or internal flags to an account;
• restricting access to individual categories, regions or listing types;
• restricting access to the account, including temporary limitation of individual features;
• requiring verification, identity confirmation or document submission;
• temporary suspension of the account for a definite or indefinite period;
• permanent blocking of the account without the right to reinstatement;
• refusal to register a new account for a person previously blocked on the Platform;
• disclosure of information to competent authorities, rights holders or affected persons in cases provided for by law.

The Platform may apply measures individually or in combination, simultaneously or sequentially, taking into account the circumstances of the specific case.

When choosing enforcement measures, the Platform may take into account the following factors:

• the nature and severity of the violation;
• the likelihood of harm to users, third parties or the Platform;
• the presence of repeated violations;
• the account history, including its age, activity, previously applied measures and warnings;
• the volume and nature of complaints received;
• the existence of related accounts, suspicious coincidences or technical signals;
• the risk to user safety, payment infrastructure or the Platform's reputation;
• the user's willingness to cooperate during the review;
• the requirements of applicable legislation and orders of regulatory authorities.

In cases of serious violations, threats to safety or clear signs of fraud, the Platform may apply strict measures immediately, without prior warning and without going through intermediate stages.

As part of moderation, verification or complaint handling, the Platform may request the user to provide the following documents and information:

• an identity document (passport, ID card, driving licence or other document);
• confirmation of a phone number, email address or other contact details;
• incorporation, registration or other documents of a legal entity or sole proprietor;
• licences, certificates, permits, clearances or other documents confirming the right to engage in a particular activity;
• documents relating to real estate, a vehicle or other property;
• proof of ownership, availability of goods, authority to post a listing or to enter into a transaction;
• explanations regarding the price, terms of the offer, description of goods or services.

Failure to provide the requested documents or explanations within a reasonable timeframe may constitute additional grounds for applying or strengthening restrictive measures.

A user may file a complaint regarding the following:

• a listing;
• another user's profile;
• a photograph, video or other media material;
• a message or behaviour of another user in correspondence;
• fraud or attempted fraud;
• intellectual property infringement;
• violation of privacy rights or personal data;
• prohibited goods, services or content;
• other violations of the Terms of Use or Platform rules.

A complaint must include:

• a link to the listing, profile, message or other subject of the complaint, or its identifier;
• a description of the alleged violation;
• sufficient information to identify the issue;
• where available — supporting materials (screenshots, documents, links).

The Platform may reject a complaint if it is filed anonymously without sufficient grounds, is manifestly abusive, constitutes mass duplicate submissions, or does not contain sufficient information for review.

Rights holders and their authorised representatives may submit notices of intellectual property infringement (copyrights, trademarks, patents, industrial designs and other protected subject matter) regarding content posted on the Platform.

A notice must include:

• the claimant's details (name, contact information, basis of authority);
• a description of the right being infringed;
• a description of the disputed content;
• a link to the disputed content on the Platform;
• an explanation of why the claimant considers the content to infringe their rights;
• supporting documents (registration certificate, power of attorney, other evidence).

The Platform may temporarily restrict access to the disputed content pending completion of the review. The Platform is not required to conduct a full legal examination of the dispute and acts within the bounds of a reasonable assessment of the materials received.

Upon receipt of a complaint about content that may pose an immediate threat to the safety, health, life or property of users or third parties, as well as content that shows signs of a criminal offence, the Platform may:

• immediately restrict access to such content;
• freeze related accounts pending clarification of the circumstances;
• restrict the user's communications on the Platform;
• request additional information from the complainant or the content owner;
• transmit information to the competent law-enforcement or regulatory authorities.

If a user disagrees with a moderation decision, a restriction or a block that has been applied, they may submit an appeal through one of the following channels:

• the support request form on the Platform;
• a dedicated appeals email address indicated in the decision notice;
• the decision review interface, if such functionality is available for the type of restriction in question.

An appeal must include:

• the account or listing identifier;
• a description of the contested decision;
• a brief statement of the reasons for disagreement;
• where available — new evidence, documents or explanations.

Filing an appeal does not automatically result in the removal of the restriction or the unblocking of the account. The appeal decision is made by the Platform based on a reassessment of the circumstances.

The Platform may reconsider a previously taken decision, including in the following cases:

• the user has provided new evidence or documents that were not available at the time the decision was made;
• it has been established that the data on which the decision was based were incomplete or inaccurate;
• the dispute is complex or ambiguous and requires further analysis;
• an automated restriction requires manual review;
• circumstances have materially changed since the original decision was made.

The Platform also reserves the right to leave a previously taken decision unchanged if it finds no grounds for reconsidering it.

The Platform may apply a temporary or permanent block to an account on the following grounds:

• systematic or serious violations of the Terms of Use or Platform rules;
• fraud, deception of users, document forgery or other bad-faith actions;
• posting prohibited, illegal or dangerous content;
• multi-accounting, use of restriction-circumvention schemes, manipulation of Platform systems;
• evasion of verification, provision of knowingly false data or documents;
• material risk to user safety, payment infrastructure or the Platform's reputation.

In cases of serious violations, a permanent block may be applied without prior warning and without going through intermediate restriction stages.

To detect multi-accounting, circumvention of restrictions, fraudulent schemes and other abuses, the Platform may use technical, behavioural, network, payment and other signals, including but not limited to:

• matches of IP addresses, devices and browser fingerprints;
• matches of contact details, payment details and addresses;
• behavioural patterns characteristic of related accounts;
• other technical and analytical indicators.

Where a connection between accounts is identified, restrictive measures may be applied to all related accounts simultaneously.

Where fraud, abuse, chargebacks, circumvention schemes or other violations related to paid services or financial transactions are identified, the Platform may:

• suspend promotion and advertising campaigns;
• cancel bonuses, promo codes and accrued credits;
• freeze access to paid features and tools;
• restrict spending of account balance and withdrawal of funds;
• delay refunds pending completion of a review;
• refuse to provide commercial features.

These measures are applied regardless of whether the user had paid and active services at the time the restrictions were imposed.

The Platform endeavours to notify the user of moderation measures taken and to provide a sufficient reason for the user to understand the nature of the restriction.

However, the Platform is not obliged to disclose the full internal assessment criteria, anti-fraud system algorithms, details of automated system operations, the list of technical signals or other information the disclosure of which may reduce the effectiveness of the Platform's protective mechanisms and create opportunities for their circumvention.

Moderation may involve probabilistic assessment, automated decisions, subjective specialist evaluation and other methods that do not preclude the possibility of errors.

The Platform makes reasonable efforts to minimise moderation errors but does not guarantee that every decision will be error-free. The appeals mechanism (Section 12) is provided, among other things, for the correction of possible errors.

The Platform shall not be liable for the consequences of restrictions applied in good faith where such restrictions were based on data, signals and circumstances available at the time the decision was made, to the extent permitted by applicable law.

The Platform may comply with lawful requests from courts, law-enforcement authorities, regulatory authorities, tax authorities and other authorised government bodies with respect to user data, content, accounts and activities on the Platform.

The Platform may also, on its own initiative, transmit information to competent authorities where there are grounds to believe that a user's actions are connected with a criminal offence, a threat to safety, fraud or other serious misconduct.

For individual listing categories, countries, regions, user types, paid services or special programmes, the Platform may establish additional or special moderation rules.

In the event of a conflict between this Policy and special rules, the special rules shall prevail to the extent directly regulated by them.

ReloSale may at any time amend, supplement, update or replace this Moderation Policy in whole or in part.

The updated version shall take effect from the date of its publication on the Platform or from such other date as is expressly stated in the document.

Continued use of the Platform after the amendments take effect constitutes the user's acceptance of the new version of the Moderation Policy.