Digital Services Act (DSA) Compliance Policy

Effective Date: 10 April, 2025

Version: 1.0

1. Introduction

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.

2. Content Moderation and Notice-and-Action Mechanisms

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.

3. Internal Complaint-Handling System and Out-of-Court Disputes Resolutions

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.

4. Single Point of Contact under the Digital Services Act (DSA)

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.

5. Terms and Guidelines

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.

6. Transparency Reporting

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 January 2026, in compliance with this obligation.