Skip to content
← All policies

Legal & safety

Content Removal & Complaints — Notice-and-Action and NCII Removal Policy

DRAFT — not yet in force; pending lawyer review. Last revised [[PLACEHOLDER: date of last revision]].

Draft for review. Replace every highlighted placeholder and have this document reviewed by qualified counsel before publishing. This is not legal advice.

1. Purpose and Scope

[[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT]] This document is DRAFT policy content for my-own-dolls.com (the "Service"), operated by [[PLACEHOLDER: legal company name]], [[PLACEHOLDER: registered address, Germany / EU]], USt-IdNr. [[PLACEHOLDER: VAT / USt-IdNr]] (the "Operator", "we", "us"). It has not been reviewed by qualified counsel and does not constitute legal advice. It must be reviewed and adapted by a lawyer before publication.

This policy explains how any person can notify us of content they believe is illegal or violates this policy, how depicted persons can request the removal of intimate imagery, and how we handle, decide, and respond to such reports. It is intended to satisfy the notice-and-action obligations of the EU Digital Services Act (Regulation (EU) 2022/2065, "DSA"), applicable German law, and the requirements of relevant payment networks for adult-content services.

The Service is a strictly 18+ adult subscription gallery. All performers depicted are verified adults. We operate a zero-tolerance policy toward child sexual abuse material ("CSAM") and toward non-consensual intimate imagery ("NCII"). This policy applies to all content made available through the Service, whether produced by the Operator or supplied by verified contributors.

2. Who Can Report — No Account Required

Anyone may submit a report or removal request, whether or not they are a registered user or subscriber. You do not need an account, and you do not need to subscribe, to notify us of content. This includes members of the public, rights holders, the person depicted in the content, that person's legal representative, child-protection or victim-support organisations, and public authorities.

Reports may be submitted in English or German. Where you are reporting on behalf of another person (for example, as a parent, guardian, lawyer, or authorised representative), please indicate the capacity in which you act. We may, where lawful and proportionate, ask for confirmation of authority, but we will not delay action on apparent CSAM or apparent NCII while such confirmation is obtained.

We aim to make reporting accessible and to avoid re-traumatising affected persons. A depicted person reporting NCII is not required to view, re-upload, or re-describe the content in graphic detail; a link, screenshot, or sufficient identifying reference is enough.

3. How to Submit a Report

Reports can be submitted through any of the following channels: (a) our online reporting form at [[PLACEHOLDER: URL of reporting/notice form]]; (b) by email to our content-complaints address [[PLACEHOLDER: complaints@ email]]; and (c) for urgent matters involving NCII or suspected illegal imagery, by email marked "URGENT" to [[PLACEHOLDER: urgent/abuse@ email]].

Reports concerning the unlawful use of an intimate image of you, or of a person you represent, can also be sent to our dedicated removal address [[PLACEHOLDER: removals@ email]]. Suspected child sexual abuse material must NOT be sent to us as an attachment; instead, report it via the URGENT channel with the URL or location reference only, and see Section 9 below.

We do not charge any fee for submitting a report or a removal request. We will acknowledge receipt of complete reports as set out in Section 6.

4. What to Include in Your Report

To allow us to act quickly and correctly, please include, to the extent you are able: (a) the exact location of the content (the URL, page, gallery, post, or media identifier — as precise as possible); (b) a clear explanation of why you believe the content is illegal or violates this policy, or, for NCII, a statement that the intimate content was shared without your consent; (c) for removal requests by a depicted person, a statement that you are (or represent) the person shown and, where you choose to provide it, information enabling us to verify identity; and (d) your name and a contact address for correspondence.

For notices alleging illegal content under the DSA, please also include, where applicable: a statement of your good-faith belief that the information in the notice is accurate and complete; and, where you are a rights holder, sufficient information to substantiate the claim (for copyright/DMCA-style notices, see Section 10). Anonymous or pseudonymous reports of apparent CSAM or apparent NCII will still be reviewed and actioned.

Providing more detail helps us assess and respond faster, but we will act on any report that gives us enough information to locate and evaluate the content. If a report is incomplete, we may contact you for clarification; for apparent CSAM or apparent NCII we will not wait for clarification before taking protective action.

5. Non-Consensual Intimate Imagery (NCII) — Priority Handling

We treat reports of non-consensual intimate imagery as a priority. NCII includes intimate, sexual, or nude images of a person that are made available without that person's consent, including content created or altered by digital means (for example, "deepfakes" or synthetic imagery) and content where consent to depiction was given but consent to publication or continued availability was not, or has been withdrawn.

Where a depicted person, or their representative, requests removal of intimate imagery on the basis that it is non-consensual, we will, on a precautionary basis, disable or restrict access to the reported content pending review, where this is technically feasible and proportionate. A depicted person who withdraws consent to the continued publication of intimate content of them is entitled to request removal, and we will honour validated withdrawal-of-consent requests in accordance with our records and applicable law.

Our approach is aligned with the goals of the NCII / image-based-abuse provisions of applicable law and with international take-down initiatives (including TAKE IT DOWN-style frameworks and recognised hash-matching programmes). Where appropriate and lawful, we may submit confirmed NCII to a recognised hash-matching service to help prevent re-upload across participating platforms. [[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT: confirm applicable national NCII statutes, e.g., German StGB provisions, and any hash-matching partner.]]

6. Acknowledgement, Triage, and Response Timeline (SLA)

We will acknowledge receipt of a complete report without undue delay, and in any event within [[PLACEHOLDER: e.g., 24–72 hours]] of receipt. We then triage reports by severity. Reports of apparent CSAM, apparent NCII, and content posing an imminent risk to a person are treated as the highest priority and are reviewed on an expedited basis, targeting initial protective action within [[PLACEHOLDER: e.g., 24 hours]].

For other reports of allegedly illegal content or policy violations, we aim to complete our assessment and notify the reporting party of the outcome within [[PLACEHOLDER: e.g., 7 calendar days]] of receiving a complete report, subject to complexity. Where a matter is complex or requires additional information, we will inform you and provide a revised timeframe.

These timeframes are internal service targets and may be adjusted in line with legal requirements and operational capacity. Nothing in this section limits any statutory deadline applicable to us. [[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT: confirm SLA figures against DSA expectations and payment-network requirements.]]

7. How We Decide and Act

We review each report against applicable law and this policy, applying decisions that are diligent, objective, and proportionate. Possible actions include: removing or disabling access to the content; restricting its visibility; demoting or de-indexing it; suspending or terminating the account or contributor responsible; refusing further uploads from a source; and, where required, reporting to the competent authorities.

We act expeditiously to remove or disable access to content we determine to be illegal or in breach of this policy. Removal of one item does not limit our right to remove related content from the same source. Where we conclude that reported content is lawful and compliant, we may decline to remove it and will explain our reasoning to the reporting party as set out in Section 8.

We process personal data contained in reports only as necessary to handle the report, in accordance with the GDPR and our Privacy Policy at [[PLACEHOLDER: link to Privacy Policy]]. Records relating to age and identity verification of performers, and to consent, are retained by our custodian of records, [[PLACEHOLDER: custodian-of-records name and contact]], in line with applicable record-keeping obligations (including, where card networks require it, controls modelled on 18 U.S.C. §2257).

8. Statement of Reasons and Notification of Outcome

Where we remove, disable, restrict, demote, suspend, or otherwise act against content or an account following a report, we will inform the affected parties of our decision and provide a statement of reasons, to the extent and in the manner required by Article 17 of the DSA and other applicable law. The statement of reasons will explain, as applicable, the action taken and its scope, the facts and circumstances relied on, the legal or contractual ground for the action, and the redress options available.

We will also notify the reporting party of the outcome of their report and of the redress possibilities available to them. Where we decline to act, we will say so and, where appropriate, explain why.

Some statements of reasons may be subject to publication in the relevant DSA transparency database where this is required of us. We will omit or redact information where publication would be unlawful, would compromise an ongoing investigation, or would endanger a person. [[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT: confirm scope of statement-of-reasons and transparency-database obligations applicable to the Operator's classification.]]

9. Anti-CSAM Reporting and Relation to This Policy

We have zero tolerance for child sexual abuse material. Any content that appears to depict, or to sexualise, a minor — whether real, altered, or synthetic — is strictly prohibited and is outside the scope of ordinary removal review. Such content is removed immediately upon detection or report and is preserved and reported to the competent authorities as required by law.

Suspected CSAM is reported to the German Federal Criminal Police Office (Bundeskriminalamt / BKA) and/or to a recognised hotline within the INHOPE network (for example, in Germany, an authorised reporting hotline), and we cooperate with lawful requests from authorities. We may preserve relevant data for the purposes of investigation and reporting, consistent with our legal obligations and the GDPR.

Please do not send suspected CSAM to us as an attachment, as redistributing such material may itself be unlawful. Instead, report the location reference through our URGENT channel (Section 3), or report it directly to the BKA, an INHOPE hotline, or your local police. [[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT: confirm exact reporting hotline, BKA reporting route, and any mandatory-reporting and data-preservation obligations.]]

10. Copyright and Other Intellectual-Property Complaints

If you believe content on the Service infringes your copyright or other intellectual-property rights, you may submit a notice through the channels in Section 3 addressed to our designated agent [[PLACEHOLDER: IP/copyright agent name and email]]. Please identify the protected work, the allegedly infringing material and its location, your contact details, and a good-faith statement that the use is not authorised, together with a statement, made under penalty of perjury where applicable, that you are authorised to act.

We respond to valid copyright notices consistent with applicable EU and German law and, where relevant to U.S.-facing intermediaries, the notice-and-takedown framework of the DMCA. We may forward the notice to the affected uploader and may reinstate content following a valid counter-notice, where the law permits.

Submitting a knowingly false or abusive notice may expose you to liability. [[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT: confirm DMCA designated-agent registration relevance and counter-notice procedure for the Operator.]]

11. Escalation, Appeals, and Redress

If you disagree with our decision — whether as a reporting party whose report was declined, or as a user or contributor affected by an action — you may appeal by contacting [[PLACEHOLDER: appeals@ email]] within [[PLACEHOLDER: e.g., 6 months]] of the decision, stating the reference number and the grounds of your appeal. Appeals are reviewed by personnel not involved in the original decision, and we will not rely solely on automated means to decide appeals.

In addition to our internal appeal, eligible users may have the right to select a certified out-of-court dispute settlement body under Article 21 of the DSA, and you retain the right to bring a claim before a competent court. You may also lodge a complaint with the relevant Digital Services Coordinator. Decisions of an out-of-court body are not binding to the extent the law provides otherwise.

Nothing in this policy limits your statutory rights. Data-protection complaints may be directed to our Data Protection Officer at [[PLACEHOLDER: DPO contact]] and, ultimately, to a supervisory authority such as the competent German data-protection authority. [[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT: confirm competent Digital Services Coordinator, supervisory authority, and any out-of-court bodies.]]

12. Misuse, Good Faith, and Youth Protection Context

Reporting tools must be used in good faith. We may decline to process, and may take measures against, reports that are manifestly unfounded, repetitive, abusive, or submitted to harass. This does not apply to, and will not deter, genuine reports of NCII or suspected illegal content, which we always take seriously.

Access to the Service is restricted to adults through an age-verification and closed-user-group mechanism designed to meet German youth-protection requirements under the Jugendmedienschutz-Staatsvertrag (JMStV). Concerns that a minor may have accessed the Service, or that age-verification controls have failed, can be reported through the channels in Section 3 and will be reviewed as a priority.

We keep this policy under review and may update it to reflect changes in law (including the DSA, GDPR, the German TDDDG/TTDSG, and the JMStV), payment-network rules (including Visa and Mastercard adult-content requirements), and operational practice. The version in force is the one published at [[PLACEHOLDER: URL of this policy]], last revised [[PLACEHOLDER: date]]. Questions about this policy may be sent to [[PLACEHOLDER: general contact email]].

Content Removal & Complaints — Notice-and-Action and NCII Removal Policy · My Own Dolls