Semly Pro, a sole proprietorship (eenmanszaak) established in the Netherlands, registered with the KvK (Dutch Chamber of Commerce) under number 99448351, VAT ID NL005387029B31, with registered address Hawaiiweg 41, 1339 NW Almere, Netherlands (trading as “SemlyPro”, “we”, “us”, “our”).
Effective date: 13 July 2026
Entity note. SemlyPro currently operates as a sole proprietorship (eenmanszaak). SemlyPro intends to incorporate a private limited company (Semly Pro B.V.). Upon incorporation, references to “SemlyPro” in this policy will be read as references to Semly Pro B.V., which will assume this policy under the assignment/novation provisions of our Terms of Service. This does not require your further consent.
1. Purpose
SemlyPro operates a hosting service for user-generated content and for Content generated by the SemlyPro Service. This policy explains how to notify us of content that you believe:
- infringes your intellectual-property rights (copyright, trade mark, or other IP); or
- is illegal under EU, Dutch or other applicable law.
It also explains what to expect after you submit a notice.
This policy implements our obligations under Article 16 of the Digital Services Act (Regulation (EU) 2022/2065) and provides a compatible intellectual-property notice mechanism. Because SemlyPro serves users worldwide, it also sets out how we act on notices under UK law (the Electronic Commerce (EC Directive) Regulations 2002 hosting defence and, where applicable, the Online Safety Act 2023), under Indian law (Section 79 of the Information Technology Act 2000 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021), and — where SemlyPro elects to rely on it — the United States Digital Millennium Copyright Act (17 U.S.C. §512). The jurisdiction-specific provisions are in Section 9.
This policy covers content generated by the SemlyPro Service (AI output) as well as content uploaded by users. This policy is a notice-and-action mechanism only; the allocation of liability where AI output infringes third-party rights is dealt with in our Terms of Service, Acceptable Use Policy and AI-output disclaimer, and is not decided by this policy.
2. Who may submit a notice
Any natural or legal person may submit a notice, including rights holders, their authorised representatives, and any person who believes content on our systems is illegal.
3. How to submit a notice
Our operative electronic notice-and-action mechanism for the purposes of Article 16 DSA is email to anil@semlypro.com. A dedicated web notice form at semlypro.com/legal/takedown will additionally be provided.
Please include the following information. Missing information will slow processing.
3.1. For all notices
- Your full name and contact information (email, and optionally postal address and phone).
- Whether you are acting on your own behalf or as an authorised representative of another party (identify the party).
- The specific URL or identifier of the content in the SemlyPro Service you are notifying about. If the content is on a customer’s site outside SemlyPro (for example, published to a customer’s WordPress site through the SemlyPro Service), we may not be the correct party to receive the notice; contact the site operator directly.
- A statement, made in good faith, that the information in the notice is accurate and complete.
3.2. Additional for IP-infringement notices
- A description of the intellectual-property right you claim has been infringed.
- Where relevant, proof of ownership (for example, a registration number, a link to the original work, or a link to the trade mark register).
- A description of how the content infringes.
- A statement that you have a good-faith belief that the use of the content is not authorised by you, your agent, or the law.
3.3. Additional for illegal-content notices
- A sufficiently detailed explanation of why you consider the content illegal, including a reference to the applicable law.
- If the content relates to Articles 3 to 7 of Directive 2011/93/EU (offences against children), you may submit anonymously.
3.4. How we handle your personal data in a notice
When you submit a notice you provide personal data (at least your name and email, and optionally your postal address and phone). We process that data solely to receive, assess and act on your notice, to communicate with you, to keep records, and to comply with our legal obligations. Please be aware that, except for anonymous reports permitted under Section 3.3, the contents of your notice — including your identity — may be forwarded to the user who provided or generated the notified content, so that they can understand the basis for any action and, where relevant, respond (see Sections 4.4 and 4.5). This processing is subject to our Privacy Policy (semlypro.com/privacy), which sets out the legal bases, retention, and your rights under the GDPR, the UK GDPR and India’s Digital Personal Data Protection Act 2023. If you object to your identity being shared, tell us in your notice; we will consider your request but may be unable to act on the notice without disclosing information that identifies you.
4. What we do with your notice
4.1. Acknowledgement
We will acknowledge receipt without undue delay and, in any event, within 24 hours of receiving a complete notice or grievance.
4.2. Assessment
We will assess the notice in a timely, diligent, non-arbitrary and objective manner, and will aim to reach a decision within 15 days of receipt (and sooner where an expedited timeline applies under Section 9). We may request additional information from you.
4.3. Action
Depending on the assessment, we may:
- remove or disable access to the notified content;
- restrict the visibility of, or demote, the notified content;
- remove, suspend or restrict the account that uploaded or generated the content;
- decline to take action, explaining our reasoning; or
- refer the matter to law enforcement or another competent authority.
Mandatory notification of criminal offences threatening life or safety (Article 18 DSA). Where we become aware of any information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of a person or persons has taken place, is taking place, or is likely to take place, we will promptly inform the law-enforcement or judicial authorities of the Member State(s) concerned and provide all relevant information available to us. Where we cannot identify the Member State concerned, we will inform the authorities of the Netherlands (our Member State of establishment) and/or Europol. This is a mandatory duty, not a discretionary action.
4.4. Statement of reasons to the affected user (Article 17 DSA)
Where we take action against content or an account, we will notify the user who provided or generated the content and give them a clear and specific statement of reasons, unless we are prohibited by law from doing so (for example, where notification would prejudice a criminal investigation). The statement of reasons will include, to the extent applicable:
- the action taken and, where relevant, its territorial scope and duration (for example, whether content was removed, disabled, demoted, or an account suspended);
- the facts and circumstances relied on in taking the decision, including whether the decision was taken in response to a notice or on our own initiative;
- where applicable, whether automated means were used in detecting or deciding on the content;
- the legal ground relied on where the content is considered illegal (with a reference to that law), or the contractual ground (a reference to the relevant term of our Terms of Service or Acceptable Use Policy) where the content is considered incompatible with our terms; and
- clear and user-friendly information on the redress options available (internal complaint-handling under Section 4.5, any out-of-court dispute settlement, and judicial redress).
4.5. Complaints — internal complaint-handling
A user who is notified of a decision under Section 4.4, and a notifier whose notice we decline to act on, may lodge a complaint through our internal complaint-handling system by writing to anil@semlypro.com. Consistent with Article 20 DSA, this complaint route is available electronically and free of charge for a period of at least six months following the date on which the affected person is informed of the decision (running from the notification under Article 16(5) or Article 17). We handle complaints in a timely, non-discriminatory, diligent and non-arbitrary manner, and decisions on complaints are taken under the supervision of appropriately qualified personnel and not solely by automated means.
This is an internal complaint-handling system under EU law and is distinct from the “counter-notification” procedure that exists under the US DMCA; if you wish to use the DMCA counter-notification route (where applicable), see Section 9.4.
Where SemlyPro is not legally required to operate an Article 20 system (see Section 9.1), we nevertheless offer this complaint route as a matter of good practice.
4.6. Further redress
If you are affected by our decision, you may also:
- use an out-of-court dispute-settlement body certified under Article 21 DSA, where such a body is available and competent — offered as a matter of good practice and without any admission that SemlyPro is an “online platform” that is legally required to submit to such settlement (see Section 9.1); and
- bring proceedings before a competent court, in accordance with the Terms of Service.
5. Repeat infringers
Users who repeatedly generate or upload infringing or illegal content will have their accounts suspended or terminated, as provided in the Terms of Service (semlypro.com/terms) and the Acceptable Use Policy (semlypro.com/acceptable-use). This cross-reference is relied on to satisfy, among other things, the “reasonably implemented” repeat-infringer requirement of 17 U.S.C. §512(i); the substantive repeat-infringer and termination mechanism lives in, and is applied under, those documents.
6. Bad-faith notices
If you knowingly submit false or misleading information in a notice, you may be liable for damages and other consequences under applicable law. We reserve the right to disregard notices we determine, in good faith, to be manifestly unfounded.
7. Contact and legal-notice address
Notices and IP/illegal-content reports: anil@semlypro.com Internal complaints (Section 4.5): anil@semlypro.com India Grievance Officer (Section 9.3): anil@semlypro.com Data-protection questions: anil@semlypro.com Security and abuse: anil@semlypro.com · anil@semlypro.com
Postal address for formal legal notice: Semly Pro (eenmanszaak), KvK 99448351 Hawaiiweg 41, 1339 NW Almere, Netherlands
DSA point of contact (Articles 11–12). For communications from Member State authorities, the European Commission, the European Board for Digital Services, and recipients of the Service in relation to this policy, our single point of contact is anil@semlypro.com. Communications may be made in English or Dutch. As SemlyPro is established in the Netherlands, no legal representative under Article 13 DSA is required.
8. Our good-faith actions and limitation of liability
8.1. To the fullest extent permitted by applicable law, SemlyPro is not liable to any notifier, affected user, customer or third party for any action taken, not taken, delayed, or reversed in good faith under this policy — including removing, disabling, restricting the visibility of, demoting, or restoring content, or suspending or terminating an account — whether done in reliance on a notice, a complaint, our own assessment, or a legal or regulatory requirement. This reflects the hosting exemption in Article 6 DSA and the “voluntary own-initiative investigations” protection in Article 7 DSA, and does not diminish any user’s own rights against the person who submitted the underlying notice.
8.2. Nothing in this policy limits or excludes any liability that cannot be limited or excluded under applicable law, including liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for intent or conscious recklessness (opzet of bewuste roekeloosheid). For consumers in the EU, the UK and India, nothing in this policy limits your mandatory statutory rights. For business customers in the UK, any limitation or exclusion of liability is in any event subject to the reasonableness requirements of the Unfair Contract Terms Act 1977 and the Consumer Rights Act 2015.
8.3. This policy is subject to, and must be read together with, the limitation-of-liability and indemnity provisions of our Terms of Service (semlypro.com/terms) and our Acceptable Use Policy (semlypro.com/acceptable-use), which are incorporated into this policy by reference. Those provisions are drafted to bind the current sole proprietorship and to carry over to Semly Pro B.V. upon incorporation.
8.4. The protections in this Section 8 are given for the benefit of SemlyPro, its owner (Surya Pillai), its co-founder Anil Varma, its personnel, contractors and agents, and — upon incorporation — Semly Pro B.V. and its officers, directors, employees and affiliates (together, the “SemlyPro Indemnified Parties”).
9. Jurisdiction-specific provisions
9.1. European Union and the Netherlands (Digital Services Act)
This policy implements Article 16 (notice-and-action), Article 17 (statement of reasons) and Article 18 (notification of criminal offences threatening life or safety) of the DSA, each of which applies to hosting services regardless of the provider’s size, including micro and small enterprises.
Articles 20 (internal complaint-handling) and 21 (out-of-court dispute settlement) are obligations of “online platforms” under Section 3 of the DSA. SemlyPro considers that it is a hosting service rather than an “online platform,” because each customer’s content is stored privately within that customer’s account and is not disseminated to the public at the recipient’s request, and that in any event SemlyPro is a micro/small enterprise exempt from the Section 3 obligations under Article 19 DSA. On that basis Articles 20 and 21 do not bind SemlyPro as legal obligations. SemlyPro nevertheless offers an internal complaint route (Section 4.5) and does not object to certified out-of-court dispute settlement (Section 4.6) as a matter of good practice.
9.2. United Kingdom
The DSA does not apply in the United Kingdom. For content accessible in the UK:
- Hosting defence. SemlyPro acts expeditiously to remove or disable access to unlawful content upon obtaining actual knowledge or awareness of it, consistent with the hosting defence in regulation 19 of the Electronic Commerce (EC Directive) Regulations 2002.
- Intellectual property. UK copyright notices are handled under the Copyright, Designs and Patents Act 1988, and trade mark and other IP notices under the applicable UK IP legislation.
- Online Safety Act 2023. The illegal-content duties under the Online Safety Act 2023 came into force on 17 March 2025 and apply to in-scope user-to-user and search services. SemlyPro’s position is that, as a private business-to-business service whose customers’ content is not shared with the public, and given its size, it is likely out of scope of the OSA.
9.3. India
For content connected to Indian users, SemlyPro relies on the intermediary safe harbour under Section 79 of the Information Technology Act 2000, read with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021. Accordingly:
- Grievance Officer. You can contact our Grievance Officer at anil@semlypro.com.
- We acknowledge grievances within 24 hours and dispose of them within 15 days of receipt.
- We remove or disable access to content within 36 hours of receiving a court order or a notification from an appropriate government agency.
- We remove content in the nature of non-consensual intimate imagery, or artificially morphed / impersonating sexual imagery, within 24 hours of a complaint.
- We endeavour to provide information or assistance to a lawfully authorised government agency within 72 hours of a valid order under the applicable rules.
Personal data contained in notices and grievances is handled in accordance with the Digital Personal Data Protection Act 2023 and the Digital Personal Data Protection Rules 2025 (notified on 14 November 2025 and phasing in); see our India Privacy & Grievance Addendum and Privacy Policy. The monthly compliance-report obligation applicable to Significant Social Media Intermediaries (5 million or more registered Indian users) does not currently apply to SemlyPro and is noted only as a future trigger.
9.4. United States (DMCA)
This Section 9.4 applies only if and when SemlyPro elects to rely on the US hosting safe harbour under 17 U.S.C. §512 and registers a designated agent with the U.S. Copyright Office.
SemlyPro’s users are worldwide, and content generated or published through the Service may from time to time be hosted or served in the United States (including via one-click publishing to US-based platforms). Where SemlyPro elects to rely on the safe harbour under 17 U.S.C. §512:
- Notice of claimed infringement. A copyright notice should contain the elements required by §512©(3): identification of the copyrighted work; identification of the allegedly infringing material and its location; your contact information; a statement of good-faith belief that the use is not authorised; a statement, under penalty of perjury, that the information is accurate and that you are authorised to act; and your physical or electronic signature. Send it to our designated agent.
- Designated agent. If SemlyPro registers a designated agent with the U.S. Copyright Office (a registration that must be renewed every three years), the agent’s name and contact details will be published here and on-site.
- Counter-notification and restoration. A user whose content was removed or disabled may submit a counter-notification under §512(g). Absent notice of a court action by the complaining party, SemlyPro may restore the material in not less than 10 nor more than 14 business days.
- Repeat infringers. SemlyPro maintains and reasonably implements a policy to terminate, in appropriate circumstances, the accounts of repeat infringers (see Section 5), consistent with §512(i).
Until such an election is made and a designated agent is registered, US notices are handled under the general mechanism in this policy.
10. Record-keeping and retention
We keep records of notices received, our assessments, statements of reasons issued, actions taken, and any complaint or restoration decisions, together with an internal moderation log. These records support our compliance with the DSA and other applicable regimes, help us defend against wrongful-takedown claims, and satisfy applicable record-keeping expectations (including UK Online Safety Act record-keeping where in scope). Records are retained for a period consistent with our Privacy Policy and with the limitation periods for potential claims.
Last updated 13 July 2026 · Operated by Semly Pro (eenmanszaak), KvK 99448351, Hawaiiweg 41, 1339 NW Almere, Netherlands · Questions about this document: anil@semlypro.com