FENRIS MEDIA LIMITED Content Monitoring Policy

1. Users of our website ("AllAccess"), Web sites and online services may not submit or upload content that is unlawful, infringes copyright, or may reasonably be considered to be harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, pornographic, libelous, invasive of another's privacy, bigoted, hateful, or racially, ethnically or otherwise offensive or objectionable.

2. Fenris Media has the right but not the obligation to monitor, screen, block, post, remove, modify, store and review such content or communications sent through AllAccess, at any time and for any reason, including to ensure that the user generated content or communications conform to the Terms of Use, without prior notice to the user.

3. Upon receipt of a notice of claimed copyright infringement from a complaining party (the Complainant):

a. The designated agent or other member of the Fenris Media team receiving the notice or message, in consultation with the legal department, shall (i) remove or disable access to the material that is alleged to be infringing; (ii) forward the written notice to any person who provided the allegedly infringing content, along with the contact information of the Complainant; and (iii) take reasonable steps to promptly notify the person who provided the allegedly infringing content, if known and if contact information is available, that Fenris Media has or will promptly disable access to the allegedly infringing material and that the person may respond with a counter notification. In consultation with the legal department, Fenris Media, may terminate the person's online account in the case of repeat allegations of copyright infringement.

b. The notice to the person alleged to have infringed a copyright shall inform that person that if he or she believes that a notice of copyright infringement has been improperly submitted against him or her by a Complainant, that person may submit a counter notification. The notice to the person alleged to have infringed a copyright can advise that to be effective, a counter notification must be a written communication containing (i) the person's physical or electronic signature; (ii) identification of the material removed or to which access has been disabled; (iii) a statement under penalty of perjury that you have a good faith belief that removal or disablement of the material was a mistake or that the material was misidentified; and (iv) the person's name, address, and telephone number.

4. Upon receipt of any report of abusive or unlawful content (not involving a notice of claimed copyright infringement) or upon otherwise independently learning or becoming aware of such content:

a. The member of the Fenris Media team will investigate the matter and will consult within the team and/or external legal counsel as needed to determine whether to remove or otherwise modify the content.

b. If the content appears facially to the Fenris Media team member investigating the matter to be unlawful or otherwise abusive or inconsistent with the Terms of Use, the Team member shall take all appropriate steps to have the content promptly removed from the Website.

c. If the content does not facially violate the Terms of Use, the Fenris Media Team member must consult within the team. The content will remain on the Website unaltered unless an executive, or their designee, determines that the content should be removed or modified.

 

Last updated: October 2022