⚠️ DRAFT — This procedure requires review by a UK-qualified solicitor before launch. Bracketed [PLACEHOLDERS] must be filled in before the Platform goes live.

Complaints Procedure

Last updated: April 2026 · Version: 1.0 (DRAFT) · Jurisdiction: United Kingdom & European Union

This Complaints Procedure is how you raise a complaint with us. It is written to satisfy the duty in the Online Safety Act 2023 section 21 on user-to-user services to operate a complaints procedure that is easy to find, easy to use, and transparent, as well as parallel requirements under the EU Digital Services Act Article 20.

If your complaint concerns a crime in progress, or an immediate risk to life — call 999 (UK) or 112 (EU) first. Come back to us afterwards so we can preserve evidence.

1. What you can complain about

You can use this procedure to raise any of the following:

  • Content that breaches our Acceptable Use Policy or Community Guidelines.
  • The conduct of another member (harassment, threats, spam, scams, impersonation).
  • An enforcement decision we have made against you (a warning, removal, suspension, or ban).
  • A billing or refund matter — see also our Refund Policy.
  • A data protection / privacy matter (access, correction, deletion, objection, portability).
  • An accessibility issue.
  • Any failure by us to comply with our duties under the Online Safety Act.
  • Anything else you believe we have got wrong.

The procedure applies equally whether you are a registered member or a non-member (for example, a person depicted in content you want removed).

2. The three routes in

We operate a three-tier model. Please start at Tier 1 — it is fastest and it is how the majority of complaints are resolved.

Tier 1 — In-product reports (fastest)

On every profile, photo, video, message, Quick Post, event, community post, and club page there is a Report button. Tier-1 reports capture the right metadata automatically (the content ID, your user ID, the timestamp, your relationship to the content) and route directly to our Trust & Safety team.

  • What we commit to: we acknowledge automatically within seconds and aim to make an initial moderation decision within 24 hours for ordinary reports and within 1 hour for reports tagged urgent (CSAM, imminent threats of violence, suicide/self-harm risk, live-stream abuse).
  • Where to go: use the ⋯ menu or the Report icon on the relevant content.

Tier 2 — Complaints email and form

For anything that is not well served by a Tier-1 in-product report — for example, an appeal against an enforcement action, a complaint about our process, a request to remove content about you uploaded by someone else, a complaint about our compliance with law — write to us:

Please include (all that apply):

  1. Your username or the email you registered with (if you are a member).
  2. Your full name and a postal address we can reply to (if you are a non-member).
  3. A short description of the complaint.
  4. The URL(s) of any content involved.
  5. The username(s) of any other member involved.
  6. What outcome you are seeking (content removal, ban, refund, apology, reinstated account, data deletion, etc.).
  7. Any evidence you wish to attach (screenshots, message logs, receipts). Do not send evidence that itself contains CSAM — report that to us via Tier 1 and we will preserve the evidence server-side. Re-transmitting CSAM is itself a criminal offence.

If you are raising a complaint on behalf of someone else — for example a child, a vulnerable adult, or a person depicted in NCII content — tell us the relationship and whether you have their authority.

Tier 3 — Escalation to an independent body

If you are not satisfied with our Tier-2 response, or if you do not receive one within the timescales set out below, you can escalate to an independent body. The right body depends on the subject-matter of your complaint — see Section 5.

3. Our service standards

For Tier-2 complaints we commit to the following:

| Milestone | Commitment | |---|---| | Acknowledgement | Within 1 working day of receipt | | Substantive first response | Within 10 working days (28 days for complex complaints — you will be told at acknowledgement which applies) | | Urgent cases (safety of a person, suspected CSAM, imminent harm) | 1 hour acknowledgement, same-day substantive action | | Data-subject-rights complaints (UK GDPR Art. 15–22) | 1 month from receipt as required by Art. 12(3), extendable once by 2 months for complex cases | | Appeals against enforcement actions | Initial decision within 7 working days | | Final decision | No more than 2 months from receipt in any case, unless the complaint is exceptionally complex and you have been told so in writing |

We will always tell you in writing when we have made a final decision and what it is. We will also tell you what further step you can take if you are not satisfied (see Section 5).

If we do not meet any of the above timescales we will explain why, tell you the new target, and offer you the option of escalating now rather than waiting.

4. How we handle your complaint

4.1 Triage

On receipt we:

  1. Log the complaint in our complaints register with a unique reference number.
  2. Acknowledge receipt to you with that reference number.
  3. Classify the complaint by type (content, conduct, enforcement, privacy, billing, accessibility, other) and by urgency.
  4. Route to the appropriate team: Trust & Safety, Privacy, Billing, Engineering, or Legal.

4.2 Investigation

A suitably qualified person who was not involved in the original decision (where the complaint is about one of our decisions) reviews:

  • your complaint and any evidence you provided;
  • the content, account, or transaction in question;
  • our original decision and the evidence that informed it;
  • any relevant policy, guideline, or law.

We may contact you for more information. We may also contact any other member involved, giving them a fair opportunity to respond where this is appropriate and does not put you at risk.

4.3 Decision

We issue a written decision that sets out:

  • what we decided;
  • why we decided it;
  • the evidence and policy we relied on;
  • the remedy (if any) — for example content removal, account reinstatement, refund, apology, process change;
  • your right to escalate (Section 5) and the time limit for doing so.

4.4 Feedback loop

We review complaint volumes and outcomes monthly and use them to improve our moderation, our product, and this procedure. Aggregate complaints data (with no personal data) is published annually in our transparency report.

5. If you are not satisfied with our decision — external escalation

You have the right to take a complaint to an independent body. The right body depends on the subject.

Online-safety / illegal content / user-to-user duties

  • Ofcom — the UK regulator for the Online Safety Act. Contact: ofcom.org.uk.
  • European Commission / Digital Services Coordinators — for users located in the EU, your national Digital Services Coordinator is the primary route under Article 53 DSA.

Data protection

  • Information Commissioner's Office (ICO) — the UK supervisory authority. Contact: ico.org.uk. You may lodge a complaint with the ICO at any stage; you are not required to exhaust our procedure first.
  • Your EU national DPA — if you are in the EU, your local supervisory authority under GDPR Article 77. A list is at edpb.europa.eu.

Consumer rights / billing / refunds

  • Financial dispute with a payment processor — CCBill operates a consumer-support line at ccbill.com/consumer-support. You can also contact your card issuer's dispute team.
  • Citizens Advice (UK) — free advice at citizensadvice.org.uk.
  • Chargeback to card issuer — we ask you to contact us first under this procedure (it is almost always faster). Filing a chargeback without contacting us first may result in your account being suspended pending the dispute.
  • Alternative Dispute Resolution (ADR) — we are not currently registered with an ADR provider for consumer disputes. If this changes we will publish the provider here.
  • EU online dispute resolution (ODR) — EU consumers may use the Commission's ODR platform at ec.europa.eu/consumers/odr.

Intellectual property

  • See our DMCA Policy for the takedown / counter-notification flow. For UK copyright, the same process is used and you retain any rights of action under the Copyright, Designs and Patents Act 1988 (including proceedings in the Intellectual Property Enterprise Court).

Court of law

  • Nothing in this procedure prevents you from bringing proceedings in a court of competent jurisdiction. Our Terms of Service set out the governing law and jurisdiction clause for contractual disputes.

6. Special categories of complaint

6.1 Non-consensual intimate images (NCII)

If you are depicted in intimate content that has been posted without your consent:

  • Use the Report button on the content, or email complaints@galerieminuit.com with the subject "NCII — urgent".
  • You do not need to prove ownership of the content. We only need enough information to satisfy ourselves you are the person depicted.
  • We aim to remove confirmed NCII within 24 hours of a credible report and will preserve evidence for law enforcement.
  • You may also use StopNCII.org to create a cryptographic hash of the content that is shared across participating platforms.

6.2 Requests to remove content about you that was posted by another member

Where the content is not intimate but is about you (for example, a profile mentions you by name), tell us in your complaint who you are and what content you want removed. We will balance your rights under UK GDPR Art. 17 ("right to erasure") and Art. 21 ("right to object") against any lawful interest of the uploader.

6.3 Complaints by or about children

If we have any reason to believe a complaint relates to a person under 18, we escalate immediately to our Child Safety lead and, where appropriate, to the National Crime Agency's CEOP referral line (ceop.police.uk).

6.4 Deceased members

Personal representatives of a deceased member may write to complaints@galerieminuit.com. We ask for a certified copy of the death certificate and evidence of your authority (for example, probate or letters of administration). UK GDPR does not apply to the personal data of the deceased, but we will act reasonably and compassionately.

7. Retaliation is not permitted

We do not retaliate against members who raise complaints in good faith. Attempting to retaliate against a complainant is itself a breach of our Acceptable Use Policy.

8. Anonymous complaints

You can raise a complaint anonymously. We will act on credible anonymous complaints, but be aware that we cannot:

  • send you updates on the outcome;
  • verify identity-dependent claims (for example, NCII-in-my-image claims);
  • apply rights that require a verified data subject (UK GDPR Art. 15–22 rights need identity verification).

9. Record-keeping

All complaints and their outcomes are logged in a secure complaints register and retained in line with our Data Retention Schedule — generally 6 years from closure.

10. Changes to this procedure

We may update this procedure as the law, Ofcom's statutory guidance, and our product evolve. Material changes will be notified to registered members by in-app notification and email at least 14 days before taking effect.

11. Contact summary

| Channel | Address | |---|---| | In-product report | Report button on any content | | Complaints email | complaints@galerieminuit.com (placeholder) | | Complaints web form | /safety/report | | Urgent / safety-critical | safety@galerieminuit.com (placeholder) | | Privacy / data protection | privacy@galerieminuit.com (placeholder) | | Post | Complaints, [LEGAL ENTITY], [REGISTERED OFFICE ADDRESS] | | Ofcom | ofcom.org.uk | | ICO | ico.org.uk — telephone 0303 123 1113 |

This document is a draft. It has not been reviewed by a UK-qualified solicitor and does not constitute legal advice. It must be reviewed against Ofcom's final statutory guidance on complaints, and against the Digital Services Act implementing provisions, before the Platform goes live.