Content and Rights Complaints Policy

1. About this Policy

This Content and Rights Complaints Policy is issued by GNR Media Pty Ltd, ABN 80 668 188 289, trading as GNR Media (GNR Media, we, us or our).

It provides a central process for reporting content that may infringe intellectual property, privacy, publicity, confidentiality or other legal rights, or that may be unlawful, dangerous or prohibited by the Terms and Conditions.

A complainant is a person or organisation submitting a notice. An affected user is a Client, member, account holder, contributor or other person whose content, account or activity is the subject of a notice or moderation decision.

2. Relationship with other documents

This Policy should be read with the Terms and Conditions, Privacy Policy, Cookie Policy, applicable plan or Order, and the Data Processing Addendum where it applies.

The Terms govern acceptable use, content licences, community participation, suspension and termination. The Privacy Policy explains how personal information in a complaint is collected, used, disclosed and retained. This Policy supplies the detailed notice, review, counter-notification and appeal process.

3. Scope

This Policy applies to content or activity that GNR Media hosts, publishes, distributes, moderates or controls through:

• GNR Media websites, landing pages, forms, funnels and public Network properties;
• the GNR Network, business profiles, Report Cards, directories, aligned stories and GNR-controlled publications;
• GNR Media community spaces, comments, posts, messages and member-contributed material;
• GNR Media-controlled social, email, video, podcast, advertising, promotional and sales channels;
• content stored or displayed through GNR Media-controlled Platform areas; and
• other content or accounts that GNR Media has the practical and legal ability to restrict, correct or remove.

This Policy does not automatically apply to a Client-owned website, social account, advertising account or third-party platform merely because GNR Media helped create or publish content there. Where the content is outside our control, we may assist or forward the complaint, but the reporter may also need to use the relevant owner or platform's reporting process.

A complaint does not require GNR Media to remove lawful content, determine a complex legal dispute, provide information without lawful authority, or take action against content we do not control.

4. What may be reported

You may use this Policy to report:

Copyright Trade marks Passing off Impersonation Privacy Image or voice Publicity rights Defamation Confidential information Misleading reviews Fraud Illegal content Serious online harm

• unauthorised copying, display, distribution or adaptation of copyright material;
• unauthorised or misleading use of a trade mark, logo, business name or brand identity;
• impersonation, false affiliation, deceptive account identity, fraud or phishing;
• unlawful disclosure or use of personal information, a person's image, voice, likeness or private material;
• material alleged to be defamatory, materially false, misleading, misattributed or presented out of context;
• misuse of confidential information, trade secrets or information subject to a legal duty of confidence;
• fake reviews, undisclosed incentives, deceptive endorsements or false commercial claims;
• harassment, threats, hate, exploitation, non-consensual intimate material or other serious online abuse;
• child sexual exploitation material, terrorist content, material facilitating serious crime, or other illegal or restricted content; and
• content or conduct prohibited by clause 17 of the Terms and Conditions.

A billing, service quality, cancellation, refund or ordinary commercial dispute should be sent to [email protected] as a support request or handled under the dispute clause in the Terms, rather than being presented as a rights complaint unless the issue genuinely concerns content or legal rights.

5. General notice requirements

Send a notice by email to [email protected]. Use the subject line Content and Rights Complaint followed by the complaint category, for example Content and Rights Complaint - Trade Mark.

A complete notice should contain:

1. your full name, organisation, role, email address and a reliable way to contact you;
2. whether you are the rights holder, an authorised representative, the person affected, or another reporter;
3. the exact URL, account, post, profile, file, page, message or other electronic location of each item complained about;
4. a clear description of the right, law, policy or contractual rule you believe is affected;
5. a sufficiently detailed explanation of why the identified content is unlawful, infringing or prohibited;
6. supporting material, such as registrations, licences, source files, dated originals, correspondence, court orders, screenshots or other evidence;
7. the country or countries whose law you say applies, where relevant;
8. the specific outcome requested, such as correction, attribution, restriction, removal, account action or preservation of evidence;
9. a statement that you have a good-faith belief that the notice is accurate and complete; and
10. your physical or electronic signature, typed name or another reliable confirmation of authority.

A person may report a serious safety or child-protection issue anonymously. An anonymous report may limit our ability to verify the allegation, provide updates or process an appeal. Do not send passwords, payment information, unnecessary identity documents or unlawful material as an attachment.

6. Copyright infringement and United States DMCA notices

A copyright owner or authorised agent may send a copyright notice to [email protected] using the subject line DMCA Copyright Notice. The same channel may be used for a non-US copyright complaint.

To be effective under the United States Digital Millennium Copyright Act where it applies, the notice must substantially include:

1. a physical or electronic signature of the copyright owner or a person authorised to act for the owner;
2. identification of the copyrighted work claimed to have been infringed, or a representative list where multiple works on one service are involved;
3. identification of the material claimed to be infringing and information reasonably sufficient for us to locate it, including each exact URL or electronic location;
4. your name, postal address, telephone number and email address;
5. a statement that you have a good-faith belief that the complained-of use is not authorised by the copyright owner, its agent or the law; and
6. a statement that the information in the notice is accurate and, under penalty of perjury, that you are authorised to act for the copyright owner.

We may contact you to complete a notice that identifies the protected work, the material complained of and reliable contact information but is otherwise incomplete. We may forward the notice, including the complainant's identity and contact details, to the affected user or a service provider involved in handling the complaint.

Where applicable, we may act expeditiously to remove or disable access to material after receiving a substantially compliant notice and will take reasonable steps to notify the affected user.

6.1 United States designated-agent status

Copyright notices may be sent to the GNR Media Copyright and Rights Contact in section 18. If GNR Media registers a designated DMCA agent with the United States Copyright Office, the agent's required public contact details will be added to this Policy. Publication of this Policy by itself is not a representation that every requirement for a United States statutory safe harbour has been completed.

7. Copyright counter-notifications

An affected user who believes material was removed or disabled because of mistake or misidentification may submit a counter-notification to [email protected] using the subject line DMCA Counter-Notification.

To be effective under the United States DMCA where it applies, a counter-notification must substantially include:

1. your physical or electronic signature;
2. identification of the material removed or disabled and the location where it appeared before removal or restriction;
3. a statement under penalty of perjury that you have a good-faith belief the material was removed or disabled because of mistake or misidentification;
4. your full name, postal address, telephone number and email address;
5. a statement consenting to the jurisdiction of the applicable United States Federal District Court or, if you are outside the United States, any judicial district in which the service provider may be found; and
6. a statement that you will accept service of process from the person who submitted the original notice or that person's agent.

We may provide the counter-notification to the original complainant. Where the United States DMCA process applies, we may restore the material not less than 10 and not more than 14 business days after receiving a substantially compliant counter-notification unless the original complainant gives us notice that court proceedings have been filed seeking an order restraining the affected user from the complained-of activity.

Outside the DMCA process, we may consider a counter-notification as an appeal under section 13 and may restore, correct, restrict or continue to withhold material based on the evidence, the Terms and applicable law.

8. Trade mark, brand, passing off and impersonation complaints

A complaint concerning a trade mark, logo, business name, brand identity, passing off or impersonation should include:

1. the exact sign, name, logo, account or representation complained about;
2. each exact URL or electronic location;
3. the trade mark registration number, jurisdiction, classes and current status, where registered rights are relied on;
4. evidence of unregistered reputation or goodwill, where passing off or similar rights are relied on;
5. an explanation of the goods, services, audience and alleged likelihood of confusion, deception or false affiliation;
6. evidence that you own the right or are authorised to act for the owner;
7. any licence, coexistence arrangement, nominative use, comparative advertising, reseller, franchise, partnership or other context relevant to the use; and
8. the precise action requested.

Trade mark ownership does not necessarily prevent every truthful reference, comparison, review, directory listing, commentary, descriptive use or display authorised by a contract. We may ask the affected user for evidence of authority or context and may require a court order where a complex ownership or confusion dispute cannot reasonably be resolved through this process.

Impersonation or fraud reports should identify the real person or organisation, explain how the disputed account or content falsely presents itself, and provide reliable evidence of identity or authority without sending unnecessary sensitive documents.

9. Privacy, personal information, image, voice and publicity-right complaints

A complaint concerning personal information, an image, voice, likeness, recording, private material or an alleged publicity right should include:

1. the exact content and electronic location;
2. the identity of the person affected and your relationship to that person;
3. the specific information, image, recording or representation in issue;
4. why the collection, use, disclosure or publication is said to be unlawful, unauthorised, inaccurate, excessive or harmful;
5. whether the material was supplied by a Client, representative, employer, account holder or the affected person;
6. any relevant consent, contract, release, privacy notice, withdrawal, objection, court order or legal restriction;
7. the country or state whose privacy or publicity law is relied on; and
8. the correction, restriction, de-identification, removal or other outcome requested.

Privacy rights are not identical in every jurisdiction. A lawful contractual licence, legitimate interest, public-interest use, reporting activity, legal obligation, freedom of expression or another legal basis may permit a use without separate consent. Equally, a person may hold a non-excludable privacy or data-protection right even where a contract applies. We will consider both the Terms and the applicable law.

A request to exercise access, correction, deletion, objection, restriction, portability or another data-protection right should also be identified as a Privacy Rights Request and will be handled under the Privacy Policy. We may process the content issue and the privacy-right request together where appropriate.

10. Defamation, materially false content, misleading reviews and confidential information

10.1 Defamation and materially false statements

A notice alleging defamation or material falsity should:

1. quote or identify each exact statement complained about;
2. provide the URL, date and context in which it appears;
3. identify the person or organisation said to be referred to;
4. explain the meaning you say an ordinary reader would take from the statement;
5. identify each material factual error and provide reliable corrective evidence;
6. explain why the statement is not protected opinion, honest opinion, fair comment, privilege, public-interest reporting or another lawful form of expression; and
7. state whether you seek correction, context, a reply, restriction, removal or preservation.

A disagreement, criticism, negative opinion or unfavourable review is not automatically defamatory. We may invite the publisher to provide evidence, context or a correction. Where a complaint requires a court to decide contested facts, reputation, privilege or legal defences, we may maintain the content, add context, restrict it temporarily or require a court order.

10.2 Reviews, testimonials and endorsements

A complaint about a review, testimonial or endorsement should explain why it is fabricated, materially altered, misattributed, incentivised without disclosure, misleading about a typical result, or not based on a genuine experience. Include the original words or evidence, the relationship between the parties and any payment, gift, commission or other material connection.

10.3 Confidential information and trade secrets

A confidentiality complaint should identify the exact information, the source of the obligation, who owed the obligation, how confidentiality was maintained, how the information was obtained, any public-domain or independently developed material, and the urgency of the requested restriction. A general statement that all business information is confidential is not sufficient.

11. Illegal, dangerous and seriously harmful content

Reports involving the following will be prioritised:

• credible threats to life, physical safety or critical infrastructure;
• child sexual exploitation, grooming or sexualised material involving a person under 18;
• non-consensual intimate imagery, sexual extortion or serious image-based abuse;
• terrorist content, instructions or recruitment;
• human trafficking, serious fraud, violent crime or content facilitating serious unlawful conduct;
• doxxing that creates a serious safety risk;
• targeted threats, severe harassment or hateful conduct likely to cause serious harm; and
• other illegal or restricted content under an applicable law or regulatory code.

Provide the exact URL, account, username, date, time, location and a short explanation of the risk. Do not download, copy, email, screenshot or attach child sexual exploitation material or other illegal sexual content. Report its electronic location only and preserve any lawful contextual information.

We may immediately restrict access, preserve records, suspend an account, notify a platform provider, contact emergency services, law enforcement, child-protection authorities or another regulator, and disclose information where permitted or required by law.

Australian users may also report serious online abuse or illegal and restricted content to the eSafety Commissioner. This does not prevent a report to GNR Media or law enforcement.

12. How GNR Media reviews and responds

12.1 Acknowledgement and triage

We aim to acknowledge a sufficiently identifiable complaint within two business days. This is a service target, not a guaranteed response time. Urgent safety reports, court orders and substantially compliant copyright notices may be prioritised. Complex or cross-border matters may take longer.

We may ask for missing information, verify identity or authority, check whether the content is within our control, preserve relevant records, and classify the matter by urgency and legal basis.

12.2 Temporary measures

Before making a final decision, we may temporarily hide, restrict, de-index, geo-block, freeze, label or preserve content, disable a link, pause monetisation, limit an account or take another proportionate measure. A temporary measure is not an admission that the complaint is correct.

12.3 Notice to the affected user

Where lawful and practical, we may notify the affected user, provide the substance of the complaint, request evidence or a response, and identify the complainant where necessary. We may withhold information where disclosure would create a safety risk, interfere with an investigation, breach a legal restriction or expose protected personal information.

12.4 Decision factors

We may consider:

• the precision, completeness, credibility and good faith of the notice;
• the apparent legal right, contractual licence, consent, authority or defence;
• the exact content, context, audience, purpose, territory and duration;
• the seriousness, immediacy and reversibility of possible harm;
• freedom of expression, public-interest, reporting, criticism, review and other lawful-use considerations;
• the affected user's explanation and supporting evidence;
• prior notices, counter-notifications, court decisions, regulator directions and patterns of conduct;
• whether a correction, label, attribution, restriction or narrower action would be sufficient; and
• the Terms, this Policy, applicable law and relevant platform rules.

12.5 Possible outcomes

We may:

• take no action;
• ask for more information or direct the complaint to the person or platform with control;
• correct, contextualise, label, attribute or update content;
• remove, disable, de-index, restrict visibility, geo-block or stop distributing content;
• preserve content but restrict access while a dispute is resolved;
• restore content following a counter-notification or appeal;
• warn, restrict, suspend or terminate an account or participation;
• refer a matter to a service provider, regulator, law enforcement body or court; or
• take another lawful and proportionate action.

Where contact details are known and disclosure is lawful, we will aim to communicate a clear decision and the main reasons to the complainant and affected user. A decision may be based on the Terms even where the content is not proven unlawful.

12.6 Automated tools and human oversight

We may use filters, matching systems, security tools, spam detection or other automation to identify, prioritise or restrict content. A contested final decision will not be made solely by an automated system where applicable law requires human oversight.

12.7 No general monitoring promise

We may moderate content proactively, but we do not promise to inspect every item, communication, link or account. The existence of this Policy does not create a general monitoring obligation or a duty to prevent every unlawful act before receiving sufficient notice.

13. Appeals and internal review

A complainant or affected user may request an internal review within six months after receiving a content or account decision. Send the request to [email protected] with the subject line Content Decision Appeal.

An appeal should include:

1. the original complaint or decision reference;
2. the content, account or action being appealed;
3. the specific finding said to be wrong;
4. new evidence, legal authority or context not adequately considered; and
5. the outcome requested.

Appeals are free. We will handle them in a timely, diligent, non-discriminatory and non-arbitrary way. Where reasonably possible, the review will be supervised by a person who was not the sole original decision-maker and will not be decided solely by automated means.

We may affirm, vary or reverse the decision, restore or further restrict content, change the duration or territory of a measure, or request additional evidence. We will aim to provide a reasoned outcome and identify any further redress available under applicable law.

Where the European Union Digital Services Act applies to the relevant service and decision, eligible users may also have access to a certified out-of-court dispute settlement body and judicial redress. Nothing in this Policy prevents a person from seeking a court order, making a regulatory complaint or exercising another right that cannot lawfully be restricted.

14. Repeat infringement, repeated illegal content and misuse of the reporting process

14.1 Repeat copyright infringement

GNR Media maintains a repeat-infringement process. Subject to good-faith counter-notifications, retractions, reversals and the available evidence, an account associated with three separate copyright removals or restrictions within a rolling 12-month period will ordinarily be considered for termination. We may act earlier for deliberate, commercial, large-scale or egregious infringement and may decide that termination is not justified where notices were mistaken, duplicated, withdrawn or credibly disputed.

We may warn the user, restrict publishing, require proof of rights, disable affected features, suspend the account, terminate access or prevent re-registration. We may also accommodate and not knowingly interfere with lawful standard technical measures used to identify or protect copyright works where applicable.

14.2 Repeated illegal or prohibited content

A user who frequently provides manifestly illegal, seriously harmful or clearly prohibited content may receive a warning, temporary restriction, suspension or termination. We will consider the number and proportion of incidents, their seriousness, consequences, duration, intent and whether the conduct continued after warning.

14.3 Manifestly unfounded or abusive notices

We may warn a complainant and, after warning, temporarily suspend processing of notices or appeals that are frequently manifestly unfounded, fraudulent, automated, harassing or submitted to suppress lawful criticism, competition, reporting or speech. We will consider the number and proportion of unfounded notices, the seriousness of the misuse, its consequences and the apparent intent.

A temporary reporting suspension will normally be proportionate to the pattern and may last from 30 to 90 days. It will not prevent us from processing a credible report of imminent harm, child safety, serious crime, a valid court order or a substantially compliant legal notice that must be considered under applicable law.

15. Information sharing, privacy and records

We handle personal information in a complaint under the Privacy Policy. By submitting a notice, counter-notification or appeal, you acknowledge that we may use and disclose the information to assess the matter, contact the parties, administer the process, protect rights and safety, comply with law and defend legal claims.

We may share relevant information with:

• the complainant, affected user, Client, account holder or content contributor;
• our personnel, contractors, hosting, platform, security and legal service providers;
• copyright owners, authorised agents, trade mark owners or other relevant rights holders;
• courts, regulators, law enforcement, emergency services and child-protection authorities;
• a person required to receive a DMCA notice or counter-notification; and
• another platform or publisher that controls the complained-of material.

Copyright notices and counter-notifications are not confidential and may be forwarded in full, subject to lawful redaction. Do not include information that is unnecessary to establish the complaint.

We may retain complaint records, evidence, decisions, correspondence, warnings and appeal outcomes for the period reasonably required for legal compliance, safety, repeat-infringer administration, limitation periods, dispute handling and defence of claims. We may retain a limited record after content is removed or an account is closed.

16. Court orders, subpoenas, regulatory requests and evidence preservation

GNR Media will respond to valid court orders, subpoenas, warrants, regulator directions and other compulsory legal process in accordance with applicable law. Legal documents should be sent to [email protected] with the subject line Legal Process - Urgent and must identify the issuing authority, proceeding, parties, required action, deadline and service basis.

Email does not waive any formal service requirement. We may require service at the registered office or another authorised address and may challenge an invalid, excessive, unclear or unlawful request.

We may preserve content, logs, account records and complaint evidence when litigation, investigation, safety risk or legal process is reasonably anticipated. Preservation does not guarantee that information exists, is complete, is within our control or can lawfully be disclosed.

If we become aware of information giving rise to a credible suspicion of a criminal offence involving a threat to life or safety, we may promptly notify an appropriate law-enforcement or judicial authority and provide relevant information permitted by law.

17. Limits of this process and preservation of legal rights

GNR Media is not a court and does not finally determine ownership, infringement, defamation, privacy liability, criminal responsibility or entitlement to damages. A moderation decision is an operational decision about content or access under the Terms, this Policy and the information reasonably available at the time.

We may decline to decide a complex dispute, preserve the status quo, restrict content temporarily, require clearer evidence, invite the parties to resolve the issue directly, or require a court or regulator to determine the matter.

Removal or restriction does not admit wrongdoing. Maintaining or restoring content does not certify that it is lawful, accurate, non-infringing or endorsed by GNR Media. A decision under this Policy does not waive the rights, remedies, defences or immunities of GNR Media or another person.

Nothing in this Policy limits a non-excludable right, prevents urgent injunctive relief, restricts a report to a regulator or law-enforcement authority, or requires a person to use this process before exercising a legal right where the law provides otherwise.

18. Contact details

GNR Media may change this Policy to reflect new services, risks, laws or procedures. A materially updated version will show a new effective or updated date. A change does not retrospectively determine a complaint already finally resolved unless required by law or agreed by the parties.