Digital Services Act (DSA) Compliance Policy
Effective Date: 10 April, 2025
Version: 1.1
The Digital Services Act (Regulation (EU) 2022/2065) establishes a harmonized framework across the European Union for the provision of intermediary services, setting out clear obligations regarding transparency, accountability, and user protection. TrafficStars Ltd, as an online advertising network and ad exchange platform, qualifies as an intermediary service provider within the meaning of Article 3(g) of the DSA.
We are committed to ensuring our continued compliance with the DSA and to upholding the principles of safety, transparency, and due diligence in our service operations. This policy outlines the measures implemented by TrafficStars Ltd in line with our obligations under the DSA.
TrafficStars operates robust compliance mechanisms, including pre-publication and ongoing moderation of ad content. This includes manual and automated reviews of creatives, landing pages, and campaign targeting parameters to prevent the dissemination of illegal or harmful content, particularly in relation to adult content.
While TrafficStars is not legally responsible for the moderation or control of the content hosted on third-party landing pages, we voluntarily extend our compliance efforts to review such external pages as part of our commitment to user safety and legal integrity. This proactive approach includes regular checks for malvertising, misleading content, and potentially illegal or non-compliant material, even where the DSA does not impose such an obligation.
Additionally, we provide clear and accessible mechanisms for users, rightsholders, and third parties to notify us of potentially illegal content or copyright infringements via dedicated reporting forms. One such mechanism is the in-ad disclosure menu, which is accessible by clicking the 'AD' label displayed in the top-right corner of each advertisement. This menu includes options such as "About the advertiser" and "Report", allowing users to easily submit a complaint or request more information directly from the ad interface.
Upon receiving a valid notice that contains sufficient information to give us actual knowledge of illegal content, our Compliance Team assesses and takes appropriate action without undue delay, in line with Articles 16 and 17 of the DSA. When we remove or restrict access to content—either following such notices or on our own initiative—we inform the affected user without undue delay, providing a clear statement of reasons for the action, including whether it was based on legal obligations or our terms, whether the decision was automated, and information on available options for redress.
In addition, in compliance with Article 26 of the DSA, we ensure that all advertisements displayed on our platform are clearly identifiable as advertisements. Each ad carries a visible 'AD' label and provides users with meaningful information about the advertiser and the main parameters used to determine why the ad is shown, enabling transparency and informed user experience.
In accordance with Article 20 of the DSA, TrafficStars has implemented an internal complaint-handling system available to service recipients (advertisers and publishers) who wish to contest decisions relating to content moderation, account suspension, or restriction of services. Complaints are handled in a timely, non-discriminatory, diligent, and transparent manner by trained compliance staff.
In addition, the service recipients may also contact a certified out-of-court dispute settlement body to help resolve any dispute with us relating to our actions on their account or reported content. The European Commission maintains a website listing the available certified settlement bodies. However, please note that decisions made by out-of-court dispute settlement bodies will not be binding on them or on TrafficStars.
TrafficStars Ltd has established a single point of contact to facilitate direct communication in accordance with the Digital Services Act (DSA).
All DSA-related inquiries—whether from Member State Authorities, the European Commission, the European Board for Digital Services, Trusted Flaggers, service recipients (advertisers and publishers) or any other who may have interest —should be submitted to legal@trafficstars.com.
Communications may be conducted in Greek or English.
In accordance with Articles 16 and 17 of Regulation (EU) 2022/2065, all advertisements disseminated through our infrastructure incorporate a user-accessible functionality that enables recipients of the service to submit notices concerning content they consider to be illegal or otherwise contrary to applicable terms and conditions.
TrafficStars maintains and enforces clear Terms and Conditions, as well as specific Guidelines for Advertisers and Publishers, which define acceptable use of our services and align with the requirements of the DSA. All service users are expected to adhere strictly to these policies.
In accordance with Article 24(2) of Regulation (EU) 2022/2065, providers of online platforms are required to publish information every six months regarding the average number of monthly active recipients of their service within the European Union. This information serves, among other purposes, to determine whether a provider qualifies as a Very Large Online Platform (VLOP) or Very Large Online Search Engine (VLOSE), defined under the DSA as services reaching more than 45 million average monthly active recipients in the EU.
Based on the six-month measurement period 1 August 2025 – 31 January 2026, the estimated average number of monthly active recipients of the TrafficStars service in the European Union was 1,963.
This information is provided solely for the purpose of compliance with Article 24(2) DSA. The methodology used to calculate monthly active recipients for DSA reporting purposes differs from the Company’s internal methodologies for measuring other metrics, including daily active users or geographic audience breakdowns. TrafficStars does not otherwise publicly disclose EU user metrics.
Measuring platform usage involves inherent methodological limitations. The figures presented above therefore reflect reasonable estimates based on available data for the relevant reporting period. These estimates may be subject to revision as methodologies evolve, including through the use of new datasets, technological developments, or changes to platform features and functionality. Consequently, metrics reported for different periods may not be directly comparable.
Under Article 15 of the Digital Services Act (DSA), TrafficStars is required to publish transparency reports detailing the content moderation activities carried out during the year. These reports must include information on notices received, actions taken, and the safeguards in place to protect fundamental rights. TrafficStars will publish its first transparency report—covering the period from 1 July 2025 to 31 December 2025—by the end of February 2026, in compliance with this obligation.