Digital Services Act – Transparency and Compliance Statement
DSA Compliance Disclosure
Nythy adheres to the European Union's Digital Services Act (DSA), ensuring transparency, accountability, user protection, and responsible digital practices across all our services.
Nythy is a digital platform that connects users with local businesses to reduce food waste. This disclosure outlines our compliance with the Digital Services Act (Regulation (EU) 2022/2065), applicable since February 17, 2024. It describes the measures we take to ensure transparency, user safety, responsible content moderation, and lawful operation of the platform.
Nythy qualifies as an "online platform" as defined in Article 3(i) of the DSA. As an intermediary service hosting user-generated content and facilitating interactions between merchants and consumers, we are subject to specific obligations under the regulation.
2.1 Services Provided
Nythy provides the following digital services:
Marketplace platform connecting consumers with local merchants (anti-waste offers)
Reservation and order system for surprise baskets and time-limited offers
Community space for sharing posts, photos, polls and recipes
Private and group messaging service between users
Free food surplus gifting between individuals
Association space for collecting food donations from merchants
Community event organization and volunteer management (associations)
Merchant space for managing offers, orders and payments (Stripe)
Geolocation features and interactive map
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
Text, image and video posts (community)
Reviews of baskets and merchants
Polls, recipes, questions and community alerts
Comments, reactions and reposts
Private and group messages (messaging)
Community groups
Each post has a visibility level set at creation: public, friends, private or community.
In compliance with the DSA, Nythy commits to the following transparency and governance obligations:
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; merchant profiles have a backend mechanism with progressive rollout in the mobile app.
Reportable items
Posts and comments
Private and group messages
Community groups
User profiles (from messaging)
Merchant profiles (API ready; "Report" button rolling out in app)
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 automated analysis (Vettly) when community posts and comments are published, and human review on reports. There is no AI moderation on messaging send.
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.
Administrators: manage roles, permissions and account suspensions
Possible moderation actions
Remove or hide reported content
Warn the author
Temporary or permanent account suspension
Pin or unpin posts
Feature restriction (e.g. reporting)
Under DSA Article 17, moderation decisions after a report (removal, restriction, suspension) generate a Statement of Reasons sent to the affected user via 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.
Priority queue for certified notifications (to be activated)
Annual publication of report volumes per trusted flagger (from first full period)
Until full rollout, reports may be sent to dsa@nythy.com 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.
Warning to reporter for manifestly abusive report (admin warn_reporter action)
Account suspension or termination for serious or repeated abuse (admin ban_reporter action)
Each restrictive measure may generate a Statement of Reasons and appeal procedure (Section 7)
Automatic reporting-limit rules (e.g. 30-day counter) are not yet coded; measures remain proportionate and traceable.
Nythy prioritizes user protection and implements strong safety, privacy, and security safeguards:
Compliance with GDPR and strong data protection standards
Secure processing of personal and transactional data
Active detection and removal of illegal or harmful content
Clear information about algorithms and recommendation logic
Respect for privacy, dignity, and fundamental user rights
4.1 Protection of Minors
Minimum age to create a Nythy account is 16, per our Terms. Age is self-declared at signup; no technical age verification is performed. Nythy does not knowingly collect data from under-16s. Identified minor accounts will be deleted. Parents/guardians may report via privacy@nythy.com.
Under DSA Article 27, we describe available ranking and filters. Nythy does not offer personalised recommendation based on advanced behavioural profiling.
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.
Community feed: createdAt (recent first), pinned posts, engagementScore tie-break
Feed filters: all / recipes / events
Offers: sort by distance, rating, price; max price filter on products
No advanced behavioural profiling or algorithmic "for you" feed
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):
Distance / search area on map and offers
Merchant and product sorting (distance, rating, price…)
Community feed filters (recipes, events)
Visibility chosen by author when creating each post (public, friends, private, community)
If Nythy displays advertisements, we comply with all related DSA transparency obligations:
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.
Target motivated response: 14 business days (not enforced by automatic timer)
If appeal admitted (overturned), lifting the restriction requires additional admin 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.
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.
The decision of the out-of-court body is non-binding for both parties
Nythy commits to engage in good faith with any certified body
The list of certified bodies is published by the European Commission and the national Digital Services Coordinators
When Nythy becomes aware of information suggesting a serious criminal offence, an internal human escalation procedure is triggered before any report to competent authorities.
In France, reports are submitted to the PHAROS platform (https://www.internet-signalement.gouv.fr) and to the Procureur de la République when relevant
Cross-border situations are escalated to Europol where appropriate
Internal escalation policy ensures qualified human review before any law-enforcement notice
7.5 Contact Points
Users and competent authorities may contact Nythy through the dedicated contact channels listed below.
In accordance with Articles 15 and 24 of the DSA, Nythy commits to publishing public transparency reports and to transmitting all moderation decisions to the European Commission's Transparency Database.
9.1 Annual Transparency Report (Article 15 DSA)
Nythy commits to publishing an annual public transparency report (/legal/transparency-report) from the first full calendar year post-launch. This report is not yet published.
Number of orders received from Member State authorities and the European Commission, broken down by category and Member State
Number of user notices submitted via the Article 16 reporting mechanism, by category and outcome
Moderation actions taken (removals, restrictions, warnings, suspensions, terminations) with category breakdown
Share of decisions made via automated tools versus human review
Number of internal complaints filed under Article 20, with reversal rate and average response time
Number of disputes referred to out-of-court bodies under Article 21
Errors identified and corrective measures applied
Reports are published once per calendar year, by 17 February 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). Hourly automated submission is in place on the infrastructure side; effective transmission depends on platform registration and Commission API key (dry-run until configured).
In accordance with Articles 11, 12 and 13 of the DSA, Nythy designates the following contact channels:
10.1 Single Point of Contact for Authorities (Article 11)
Nythy designates dsa@nythy.com 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 support@nythy.com. 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.
Stripe Connect Express: KYC, IBAN and documents (Stripe interface)
SIRET cross-check with public registers when provided
Admin decisions traced; rejection or suspension with reasons
12.3 Public display of trader information (Article 30(2) DSA)
Once verified, each trader's commercial name, registered address and SIRET are displayed on a public profile accessible to consumers, alongside the products offered. This ensures that consumers can identify the trader they enter into a contract with.
12.4 Suspension and removal
If Nythy obtains information indicating that a trader has provided unreliable, incomplete or inaccurate information, the trader is required to correct the information without delay. If the trader fails to comply, Nythy will:
Suspend the trader's ability to offer products or services on the platform
Notify the trader of the suspension with reasons and remedies (including the right to appeal under Article 20)
Maintain the suspension until the corrected information is provided and verified
Where applicable, notify the competent national authorities (DGCCRF in France) of the case