Declaration of
DSA compliance

2.1 Services Provided

Nythy provides the following digital services:

2.2 Users and Hosted Content

Users may publish various types of content on the platform. Under DSA Article 6, Nythy acts as a technical host and is not liable for user-generated content until we receive an illegality notification.

Hosted content types

Each post has a visibility level set at creation: public, friends, private or community.

3.1 Clear and Accessible Terms of Use

Nythy provides clear, accessible, and easily understandable terms of use, available to users at any time before and after registration. The terms outline user responsibilities, content rules, moderation policies, and restrictions applicable on the platform.

3.2 Reporting System (Article 16 DSA)

Users may report content suspected to be illegal or contrary to our terms. Reporting is available from relevant content (posts, comments, messages, groups). User profiles can be reported from messaging; reporting of merchant profiles is progressively rolling out in the mobile app. A peer-to-peer gift can be reported by its recipient after pickup, from the received donations page.

Reportable items

Each report receives a status: pending → under review → resolved or dismissed. The reporter is notified when the case is closed (no persistent automatic acknowledgment on submission alone).

3.3 Moderation Process (Articles 14 and 17 DSA)

Moderation combines automatic analysis (Vettly) — when community posts and comments are published, as well as on images shared in private messaging (analyzed before display) — and human review upon report. Text and audio messages are not subject to automated moderation at sending.

If Vettly rejects content at source, it is not published. This pre-publication rejection does not currently generate a separate Statement of Reasons; an error is returned to the author.

Moderation roles

Possible moderation actions

Under DSA Article 17, moderation decisions after a report (removal, restriction, suspension) generate a Statement of Reasons sent to the affected user via an in-app notification.

Target report handling: 48 business hours. Manifestly illegal content is prioritised by the moderation team.

3.4 Trusted flaggers (DSA Article 22)

Nythy plans to prioritise reports from trusted flaggers designated by Member States' digital services coordinators. This mechanism is being rolled out post-launch.

Until full rollout, reports may be sent to [email protected] or via the standard reporting mechanism.

3.5 Measures against abusive use (DSA Article 23)

To preserve reporting integrity, Nythy applies graduated measures — mainly through human moderation — against manifestly unfounded reports or repeatedly manifestly illegal content.

Measures limiting the reporting function remain proportionate, justified and traceable.

4.1 Protection of Minors

The minimum age to create a Nythy account is 16, in accordance with our Terms of Use. The minimum age is explicitly certified by the user at account creation; however, no technical age verification is carried out. Nythy does not knowingly collect data from minors under 16. If a minor's account is identified, it will be deleted. Parents or guardians can report a minor's account via [email protected].

5.1 Feed ranking and offer sorting

The community feed is mainly ordered by publication date (newest first), with pinning, geographic proximity where applicable, and engagement score as a secondary tie-break. Offers and merchants can be sorted by distance, rating, price and other in-app criteria.

Nythy does not perform advanced behavioural profiling. Ranking uses objective, transparent criteria.

5.2 Available user settings

Users can adjust some display settings in the app (depending on screens):

6.1 Identification of Advertising

Any third-party advertising would be clearly labelled. Nythy does not currently display external programmatic ads; some internal promotional content (e.g. sponsored posts or merchant highlights) is labelled in the interface where applicable.

6.2 Information About Advertisers

Where advertising is displayed, users are informed about the identity of the advertiser and the targeting criteria used, in accordance with Article 26 of the DSA.

7.1 Content Reporting (Article 16 DSA)

Any user can report potentially illegal or rule-violating content via the 'Report' button available on each piece of content.

On-screen confirmation on submission; reporter notified when the report is closed (resolved or dismissed).

7.2 Appealing Moderation Decisions (Article 20 DSA)

Any user affected by a moderation decision may contest a Statement of Reasons within 6 months, free of charge.

How to submit an appeal

1. Review by a human moderator (goal: different from initial decision-maker, not technically guaranteed)
2. Statuses: pending → under review → upheld or overturned
3. Target motivated response: 14 business days (not enforced by automatic timer)
4. If the appeal is upheld, lifting the restriction requires additional administrative processing

In accordance with Article 17 of the DSA, every removal or restriction decision is accompanied by a clear explanation of reasons (Statement of Reasons), including the legal basis, facts and available remedies.

7.3 Out-of-Court Dispute Resolution (Article 21 DSA)

If the internal complaint does not lead to a satisfactory outcome, the user has the right to bring the dispute before a certified out-of-court dispute settlement body, without prejudice to the right to bring legal action.

https://digital-strategy.ec.europa.eu/en/policies/dsa-out-court-dispute

7.4 Reporting Suspected Criminal Offences (Article 18 DSA)

When Nythy becomes aware of information suggesting a serious criminal offence, an internal human escalation procedure is triggered before any report to competent authorities.

7.5 Contact Points

Users and competent authorities may contact Nythy through the dedicated contact channels listed below.

9.1 Annual Transparency Report (Article 15 DSA)

Nythy commits to publishing an annual public transparency report from the first full calendar year post-launch. This report is not yet published and will be made available on this page as soon as its first edition is released.

Reports are published once per calendar year, by February 17 following the reporting period.

Reports are made available in human-readable HTML and machine-readable CSV formats to support independent research.

9.2 EU Transparency Database (Article 24(5) DSA)

Statements of Reasons under Article 17 are prepared for transmission to the Commission transparency database (https://transparency.dsa.ec.europa.eu). A regular automated transmission is planned; its activation depends on the platform being registered with the Commission.

10.1 Single Point of Contact for Authorities (Article 11)

Nythy designates [email protected] as its electronic single point of contact for the Member States authorities, the European Commission and the European Board for Digital Services. Communications may be submitted in French or English.

10.2 Single Point of Contact for Users (Article 12)

Users may contact Nythy through the in-app help center, the contact form available at https://nythy.com/contact or directly by email at [email protected]. Communications are accepted in French and English.

10.3 Legal Representative in the EU (Article 13)

Nythy is established in France and therefore has its primary place of establishment within the European Union. As such, the obligation to designate a legal representative under Article 13 DSA does not apply.