Moderation and Appeals Policy

⚠️ DRAFT. Must be reviewed by a lawyer before publication. This is prepared text, not legal advice.

Version: 2026-08-22 · Effective: to be confirmed

Part of the Terms of Service. What is prohibited is in the Community Guidelines. This document is about how we apply that, and how you can argue with us.

1. Two separate cycles, not "a bot that sees everything"

Our moderation is two independent mechanisms. Mixing them up is harmful: they have different surfaces, different costs and different ethics.

	The gate	The response
Covers	what a school publishes for everyone: welcome video, descriptions, free previews, cover images, pinned announcements	everything else, including live conversation
Triggered	before publication	by your report
How	a check + a human (today the check is manual, see below)	a human
Initiated by	the platform	you

🔴 Today the "gate" is a person, not automation. The automated check is described here as the shape of the mechanism and as a promise about the appeal route; until it is switched on, published material is reviewed by hand. When it is switched on, the rule in §3.4 — a human takes the final decision — applies from day one rather than being added later.

There is no blanket scanning of conversations, and none is planned. That is not an omission but a decision: the platform cannot read encrypted rooms, and we do not intend to change that.

2. What we are physically able to see

Where	Can we see content
Encrypted rooms (private and group)	No. Keys are only on devices
A school's announced common rooms (marked)	Yes — deliberately unencrypted, otherwise they could not be moderated
What a school publishes	Yes, and we check it before publication
Metadata: who, when, where	Yes

A room with automated message checking says so openly. No marking means no checking.

The practical consequence: we learn about a violation in an encrypted room only from you. A report is therefore not a formality but the only channel.

3. The gate: checking what is published

3.1 What is checked

A school's welcome video, descriptions of the school and its products, free preview lessons, cover images, pinned announcements.

This is a finite and small list — what a newcomer sees first. The whole lesson archive is not transcribed for moderation purposes.

3.2 What we look for

Two independent classes, which must not be collapsed into a single "bad":

Prohibited material — from the zero-tolerance list and the prohibitions in the community guidelines.
Steering to payment outside the app — mentions of a website, of "payment", "buy", "subscription", of domains and prices in a purchasing context. Why this is a separate class: for this the store removes the entire app, not a single course. The explanation for schools is in the Teacher Agreement, §5.

To check speech in a video it is converted into text. This is processing of personal data and is declared in the Privacy Policy, §4.12.

3.3 Procedure

The school uploads material → "under review", not visible to students.
The check is clean → it is published.
The check flags something → a refusal with a reason in plain language, pointing to the specific place in the material, with an invitation to correct it.
The school disagrees → appeal (§6).

3.4 🔴 Automation does not decide finally

A rejection by the automated check is a preliminary decision. It can always be reviewed by a human on the school's request, and we never refuse such a review.

This is required by Art. 22 GDPR: a decision significantly affecting a person may not be purely automated.

Automation errs predictably: a lesson about one's relationship with money is full of the word "payment". That is why a refusal must point to a place rather than pronounce a verdict on the whole item.

4. The response: reports

4.1 How to report

In the app: message menu or member card → "Report" → choose a reason and add an explanation if you wish.
By email: to be confirmed — works without the app and without an account.

A report about a whole school or about a teacher goes to the platform operator, not to the school itself. Nobody reviews a report against themselves.

4.2 🔴 What travels with a report

If you report a message from an encrypted room, your device attaches a decrypted excerpt of the conversation. Otherwise there is nothing to review: the server sees ciphertext.

This means you are passing us the content of that excerpt, including other people's words. We use it only to handle the report and delete it to be confirmed days after the case closes. The app warns you about this before sending.

4.3 Timelines

What	Period
Acknowledgement of receipt	to be confirmed hours
Reasoned decision	to be confirmed days
Threats, sexual content involving children, immediate danger	immediately, around the clock
Answer to an appeal	to be confirmed days

If we miss a deadline, write to to be confirmed — that is a separate channel.

4.4 How a report is handled

We check that the report concerns our service and is intelligible.
We look at the reported item and its context.
We give the affected person a chance to respond — except in cases of immediate danger, and where warning would allow evidence to be hidden.
We decide and write to both sides: what was decided, on what basis, and how to appeal.

A human takes the decision. Automation may flag and prioritise a report but cannot close it.

4.5 What we can do

In ascending order:

Reject the report — explaining why.
Warn the author.
Remove the message or item.
Restrict: a temporary ban on writing in a room.
Remove from a room or from a school.
Block the platform account.
Switch off a school's sales or terminate its agreement.
Refer the material to law enforcement.

The choice depends on severity, repetition and intent. The zero-tolerance list starts at step 5–6.

4.6 False and mass reports

A report is not a weapon. Systematically unfounded reports, reports filed to apply pressure, and coordinated campaigns against a person are themselves a violation and lead to a restriction of the ability to report.

We warn before imposing such a restriction, except in obvious campaigns.

5. Blocking another user — your own tool

Separately from reports: you can block a person yourself, without asking anyone. Their messages stop being visible to you, immediately.

Honestly about the limits:

blocking hides messages from you but does not remove the person from the room;
they still see the room and read others;
only school staff can remove someone from a room.

We do not tell a blocked person that they were blocked. Your block list is in settings, and you can undo it at any time.

6. 🔴 Appeals

You can appeal any decision of ours: removal of material, refusal to publish, a restriction, removal, blocking of an account, switching off sales, and also a refusal of your own report.

6.1 How

By email to to be confirmed within to be confirmed days of receiving the decision. Set out what you disagree with, on the merits.

6.2 What we guarantee

The appeal is reviewed by a human. Not by automation, and not by the same system that made the original decision.
Where possible, by someone not involved in the original decision. We are a small team and cannot always ensure this; when we cannot, we say so plainly.
A written answer with reasons within to be confirmed days.
If the decision is reversed we restore everything that was restricted. A school whose sales were suspended without justification is compensated for the loss.

6.3 When enforcement is not suspended

An appeal does not delay enforcement where there is immediate danger: threats, sexual content involving children, an active attack on the service, a requirement from a public authority. There we stop the harm first and examine afterwards.

6.4 If our answer does not satisfy you

On data protection: Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, dsb.gv.at, or the supervisory authority where you live.
On the substance of a decision: out-of-court procedure to be confirmed, or the courts — §14 of the Terms of Service.
On an app store decision (where material was removed at its demand): that decision is the store's and must be challenged with it; we will help with the facts.

7. Our duties as a platform

We are a small platform and fall within the micro-enterprise exemption under the EU Digital Services Act. Nevertheless we maintain:

a point of contact for users and authorities — to be confirmed;
a description of content restrictions in plain terms — the community guidelines;
a notice and action mechanism — §4 of this document;
a reasoned decision to each side — §4.4;
notification of suspected criminal offences to law enforcement where life or safety is at risk.

As a micro-enterprise we are not obliged to run an internal complaint-handling system under DSA Art. 20 — but we run one voluntarily (§6), because a decision without an appeal is badly designed regardless of the law.

8. Who decides

Reports about messages and members inside a room are handled in the first instance by school staff. Reports about a school itself, about a teacher, and all appeals are handled by the platform operator, to be confirmed.

Every action by staff and by the operator is written to an immutable log: who, when, what and on what basis. The log is kept for 3 years.

9. Transparency

At least once a year we publish a short report at https://seva.seetouch.me: how many reports were received, in which categories, how many were upheld, how many appeals there were and how many decisions were reversed. Without names and without content.

10. Changes

Material changes are announced 14 days in advance. Previous versions stay published.

11. Contact

Reports: to be confirmed · Appeals and claims: to be confirmed · Support: to be confirmed to be confirmed, to be confirmed, Austria

The source version is Russian: 07-moderation-policy.ru.md.

“To be confirmed” in place of a detail means exactly that: the value has not been filled in yet. We do not put invented data here.