Copyright & DMCA Policy

Last updated: 30 August 2026

This Copyright & DMCA Policy explains how Symploka s.r.o., operating under the Grablex brand, handles reports alleging copyright infringement and other intellectual-property issues in connection with Grablex Services.

Grablex respects intellectual-property rights and expects Customers and users to do the same.

This Policy addresses:

• copyright and related-rights reports;
• hosting/content restrictions;
• Customer responses and review;
• EU and Czech copyright rules;
• the Digital Services Act notice-and-action framework;
• U.S. Digital Millennium Copyright Act (“DMCA”) procedures where applicable;
• repeat infringement;
• domain-name and trademark distinctions;
• and upstream-provider escalation.

This Policy should be read together with our:

• Terms of Service;
• Acceptable Use & Abuse Policy;
• Privacy Policy;
• Digital Services Act Notice;
• Data & AI Transparency Notice;
• and applicable service-specific terms.

PROVIDER IDENTITY

1. Operator

Grablex is operated by:

Symploka s.r.o.

Country:

Czech Republic

Company identification number (IČO):

30173833

Primary website:

grablex.com

Current general copyright/legal contact:

contact@grablex.com

Telephone / SMS:

+420 734 627 827

A dedicated copyright or DMCA address may be published later after it is operational and verified.

SCOPE

2. Services covered

This Policy may apply to copyright or intellectual-property issues involving:

• websites hosted through Grablex;
• Customer content;
• files stored through applicable Services;
• cloud or server Services;
• SaaS features;
• public content hosted directly by Grablex;
• links or references controlled by Grablex;
• Grablex-owned websites;
• and other Grablex Services where relevant.

The legal framework and available remedy depend on Grablex's actual role in relation to the material.

3. Content not controlled by Grablex

Grablex cannot remove content from a third-party service merely because a Customer or reporter can view that content through the internet.

Where Grablex does not host, control, cache, link through a controlled service, register the relevant domain or otherwise have a role that permits action, Grablex may direct the reporter to the appropriate service provider or rights-enforcement process.

CUSTOMER RESPONSIBILITY

4. Customer content

Customers must ensure that content they upload, publish, distribute or instruct Grablex to use does not unlawfully infringe third-party intellectual-property rights.

This can include:

• text;
• photographs;
• illustrations;
• graphics;
• video;
• music;
• audio;
• fonts;
• software;
• databases;
• designs;
• templates;
• logos;
• trademarks;
• datasets;
• and other protected material.

5. Customer-supplied material

A Customer who provides material to Grablex for a Project or hosted Service is responsible for having the rights, licences, permissions or lawful basis needed for the intended use, subject to the Terms of Service and mandatory law.

6. Licences and lawful exceptions

Use of a protected work is not necessarily infringing merely because the user is not the copyright owner.

Depending on applicable law and facts, use may be lawful because of:

• a licence;
• authorisation;
• public-domain status;
• an applicable statutory exception or limitation;
• quotation;
• criticism;
• review;
• caricature;
• parody;
• pastiche;
• fair use under U.S. law where applicable;
• or another lawful basis.

Grablex does not treat every allegation as conclusive proof of infringement.

EU / CZECH COPYRIGHT FRAMEWORK

7. Czech law

Grablex is operated by a Czech company and therefore assesses relevant obligations under applicable Czech and European Union copyright law.

The Czech Copyright Act is:

Act No. 121/2000 Coll., Copyright Act (Autorský zákon), as amended.

Applicable law for a particular dispute may also depend on the territory, parties, service and alleged infringement.

8. Digital Single Market copyright rules

Directive (EU) 2019/790 contains a special regime for online content-sharing service providers (OCSSPs).

An OCSSP is not simply any company that hosts a website or stores Customer data.

The definition concerns an information-society service whose main or one of its main purposes is to store and give the public access to a large amount of copyright-protected works or other protected subject matter uploaded by users, which the provider organises and promotes for profit-making purposes.

9. Services excluded from the OCSSP definition

EU and Czech law exclude categories including:

• business-to-business cloud services;
• cloud services that allow users to upload content for their own use;
• online marketplaces;
• open-source software development/sharing platforms;
• specified non-profit encyclopaedias;
• specified non-profit educational/scientific repositories;
• and electronic communications services.

Accordingly, ordinary Grablex hosting or B2B cloud Services are not automatically OCSSPs.

10. Future public user-content products

If Grablex later launches a Service whose main purpose includes organising and promoting large amounts of user-uploaded copyright content to the public for profit, Grablex will perform a separate OCSSP classification and compliance review before launch.

Possible examples could include a qualifying public:

• media-sharing platform;
• image/video platform;
• user-content feed;
• or other content-sharing Service.

REPORTING COPYRIGHT INFRINGEMENT

11. Copyright reporting

A person who believes that content handled through a Grablex Service infringes copyright may send a report through:

contact@grablex.com

or through the dedicated electronic copyright/abuse reporting interface when it becomes available.

For hosting Services subject to Article 16 DSA, the reporting interface is designed to meet the applicable electronic notice-and-action requirements.

A reporter does not need to purchase a Grablex Service merely to submit an applicable illegal-content notice.

12. Information to provide

To allow a diligent review, an ordinary copyright report should include, as applicable:

1. identification of the copyrighted work or protected subject matter;
2. a description of the reporter's ownership, authority or other entitlement to act;
3. the exact URL or other electronic location of the allegedly infringing material;
4. a sufficiently substantiated explanation of why the use is alleged to be unlawful;
5. relevant supporting evidence;
6. the reporter's name and email address;
7. a good-faith statement that the information and allegations are accurate and complete;
8. and, for a U.S. DMCA notice where applicable, the additional statutory elements described later in this Policy.

13. Exact electronic location

A copyright notice should identify the material precisely enough to permit Grablex to locate it.

Examples may include:

• exact URL;
• specific page;
• file/object identifier;
• path;
• hosting resource;
• or another exact electronic locator.

A broad request such as “remove everything from this Customer” may be insufficient where the allegedly infringing material is not specifically identified.

14. Identification of the original/protected work

Where reasonably available, the reporter should identify the original protected work through information such as:

• original URL;
• publication;
• registration information;
• licence records;
• source files;
• portfolio;
• catalogue;
• or another reliable description.

A copyright registration number is not automatically required for every copyright report.

15. Evidence of authority

A reporter acting for another rights holder should have authority to do so.

Grablex may request reasonable evidence of:

• ownership;
• exclusive rights;
• representation;
• licence;
• assignment or chain-of-title transfer where legally possible;
• exclusive licence or other entitlement;
• collective-management authority;
• or another relevant legal interest

where needed to evaluate a disputed claim.

REVIEW

16. Initial review

Grablex may review:

• whether the report identifies specific material;
• whether the material is controlled through a Grablex Service;
• whether the claim concerns copyright or another right;
• whether the report is sufficiently substantiated;
• whether there is an apparent licence, exception or other lawful basis;
• whether an upstream provider is involved;
• and whether urgent action is required.

17. No automatic claimant victory

Submitting a copyright complaint does not automatically establish ownership or infringement.

Where the issue requires substantial factual or legal determination, Grablex may:

• seek additional information;
• ask the affected Customer for a response;
• restrict content where legally required or justified;
• preserve the status quo where lawful;
• refer parties to an appropriate court or dispute-resolution body;
• or take another proportionate action.

18. Obvious or urgent infringement

Where a claim is sufficiently clear and action is legally required or appropriate, Grablex may act expeditiously.

Actions may include:

• disabling access to the specific material;
• removing material under Grablex's control;
• requesting Customer removal;
• temporarily restricting a resource;
• suspending a feature;
• or escalating to an upstream provider.

19. Proportionality

Where practical and lawful, Grablex seeks to target the specific infringing material rather than unnecessarily disabling an entire:

• website;
• server;
• account;
• or domain.

Broader action may nevertheless be appropriate for:

• repeated infringement;
• deliberate piracy;
• pervasive infringement;
• fraudulent activity;
• inability to isolate the material;
• court/authority orders;
• upstream requirements;
• or other serious circumstances.

DSA RELATIONSHIP

20. Article 16 DSA

Where Grablex acts as a hosting-service provider within Article 16 DSA, copyright allegations concerning illegal content can be submitted through Grablex's notice-and-action mechanism.

Applicable notices are handled in a:

• timely;
• diligent;
• non-arbitrary;
• and objective

manner.

21. Acknowledgement and reporter decision

Where an applicable Article 16 notice contains electronic contact information, Grablex sends a confirmation of receipt without undue delay.

Grablex also notifies the reporter without undue delay of the decision concerning the reported information and provides information on available redress as required by Article 16.

22. Automated tools

Grablex may use automation or AI to:

• classify notices;
• locate duplicated reports;
• identify URLs;
• detect obviously matching files;
• or prioritise review.

Where DSA disclosure of automated processing or decision-making is required, Grablex includes the relevant information in the applicable notification.

23. Statement of reasons to the affected Customer

Where Article 17 DSA applies and Grablex restricts Customer-provided information because it is considered illegal or incompatible with the Terms, Grablex provides the affected recipient with the applicable clear and specific statement of reasons.

This may include:

• the affected material/resource;
• restriction;
• facts and circumstances;
• legal or contractual ground;
• whether a notice triggered the decision;
• use of automated means;
• and available redress.

24. Reporter identity

A reporter's identity is not automatically disclosed to the Customer.

Article 17 DSA contemplates disclosure of notifier identity only where strictly necessary in the relevant circumstances.

Grablex therefore seeks to balance:

• fair notice;
• defence rights;
• privacy;
• safety;
• confidentiality;
• and legal requirements.

CUSTOMER RESPONSE / REVIEW

25. Customer response

A Customer affected by a copyright restriction may respond through the review route communicated with the decision or through:

contact@grablex.com

The response may include:

• evidence of ownership;
• a licence;
• permission;
• proof of public-domain status;
• applicable statutory exception;
• identification error;
• evidence that the wrong URL/file was reported;
• or another relevant explanation.

26. General review is not a DMCA counter-notice

A Grablex contractual/DSA review request is different from a statutory U.S. DMCA counter-notification.

The formal DMCA counter-notification procedure described below applies only where the relevant U.S. DMCA framework is being used.

FALSE, ABUSIVE OR DEFICIENT REPORTS

27. Incomplete reports

Grablex may request missing information where a report does not contain enough information for a reliable decision.

Where a U.S. DMCA notice contains certain core information but is otherwise deficient, applicable §512 procedures may require reasonable assistance or an attempt to obtain the missing statutory information rather than simply disregarding the notice.

28. Misuse

Copyright reporting mechanisms must not be used to:

• silence lawful criticism;
• remove a competitor;
• suppress lawful reviews;
• target material the reporter does not own;
• impersonate a rights holder;
• knowingly misrepresent infringement;
• or otherwise abuse the process.

Grablex may reject, limit or investigate abusive reports where permitted by law.

29. Fraudulent notices

Grablex may preserve evidence and take action against deliberately fraudulent or malicious notices, subject to applicable law.

U.S. law may impose liability for certain knowing material misrepresentations in a DMCA notice or counter-notice.

TRADEMARKS AND OTHER IP

30. Trademark is not DMCA copyright

The DMCA notice-and-counter-notice procedure described in 17 U.S.C. §512 concerns copyright.

A complaint about:

• a trademark;
• trade name;
• patent;
• trade secret;
• design right;
• personality right;
• or unfair competition

is not automatically a DMCA copyright claim.

31. Other IP reports

Grablex may accept reports concerning other intellectual-property rights through the abuse/legal reporting process.

Different evidence, legal standards and remedies may apply.

Grablex may require legal review before taking action in disputed trademark, patent or trade-secret matters.

DOMAIN NAMES

32. Domain name versus hosted content

The domain name and content hosted at that domain are separate technical and legal layers.

For example:

`example.com/file.jpg`

may involve an allegation against the hosted file without automatically justifying cancellation or transfer of the `example.com` registration.

33. Trademark-based domain disputes

Trademark-based disputes concerning the registration/use of a generic top-level domain may be subject to:

• the ICANN Uniform Domain Name Dispute Resolution Policy (UDRP);
• the Uniform Rapid Suspension System (URS) where applicable;
• court proceedings;
• registry-specific procedures;
• or another applicable dispute process.

Most trademark-based domain ownership disputes should not be converted into a copyright takedown merely because the claimant prefers that procedure.

34. Domain-level action

Grablex or an upstream registrar may take domain-level action where supported by:

• a valid court or authority order;
• a UDRP/URS or other applicable decision;
• registrar/registry rules;
• malicious registration/use;
• fraud/abuse;
• repeated serious violation;
• contractual terms;
• or another lawful basis.

OPENPROVIDER

35. Upstream domain provider

Grablex may use Openprovider / Hosting Concepts B.V. as an upstream registrar/domain provider.

Openprovider's current Terms prohibit intentional infringement of third-party rights and include copyright, trademark, patent, trade-secret and other proprietary-right violations within its abuse rules.

Openprovider remains an independent upstream provider.

36. Escalation to Openprovider

Where a complaint concerns a domain registered or managed through Openprovider, Grablex may:

• investigate within its own role;
• communicate with the Customer;
• refer/escalate the matter to Openprovider;
• comply with applicable registrar/registry procedures;
• or implement an upstream action that Openprovider lawfully requires.

A domain-level escalation does not mean that a complainant automatically obtains transfer or cancellation of the domain.

HETZNER

37. Upstream hosting infrastructure

Grablex may use Hetzner as an upstream infrastructure provider.

Hetzner's current terms prohibit Customer content that infringes third-party rights, including copyright and trademark rights.

38. Hetzner abuse reports

Where Hetzner sends Grablex an abuse or copyright-related notice concerning a Grablex-managed resource, Grablex may:

• identify the affected Customer/resource;
• investigate;
• request remediation;
• restrict content/service where appropriate;
• reply to Hetzner;
• and preserve necessary evidence.

An upstream Hetzner action may be independent of Grablex's own DSA or copyright assessment.

AI-GENERATED CONTENT

39. AI does not create blanket immunity

A statement that material is “AI-generated” does not automatically prove that the material is free of third-party rights.

AI output may contain or resemble:

• protected expressions;
• trademarks;
• copyrighted input;
• licensed material;
• human-authored material;
• or other protected content.

40. AI complaints

Copyright complaints involving AI-generated or AI-assisted material are assessed using the same principles of:

• ownership/right;
• actual material;
• applicable law;
• licence;
• exceptions/limitations;
• and evidence.

Grablex's separate Data & AI Transparency Notice applies to AI processing and provenance issues.

Grablex INTELLECTUAL PROPERTY

41. Grablex materials

Unless otherwise stated or contractually agreed, intellectual-property rights relating to Grablex-owned materials may include rights in:

• website content;
• software;
• documentation;
• graphics;
• interface designs;
• templates;
• trademarks;
• logos;
• mascots;
• and other original material.

42. Customer Projects

Ownership and licensing of Customer Projects are governed by:

• the Terms of Service;
• applicable Quote/SOW;
• specific licence terms;
• Customer-supplied-material rules;
• and applicable law.

This Policy does not alter those contractual rights.

U.S. DMCA LAYER

43. Conditional application

Where U.S. law applies or Grablex elects to operate a U.S. DMCA §512 process for an eligible online-service-provider function, the procedures in this section may apply in addition to the EU/Czech framework.

The DMCA contains safe harbors for qualifying categories of online service providers, subject to statutory conditions.

44. No automatic safe-harbor representation

The existence of this Policy does not itself mean that:

• Grablex has registered a U.S. DMCA Designated Agent;
• every Grablex Service qualifies under §512;
• or every statutory condition for a §512 safe harbor has been satisfied.

Where Grablex has a current registered DMCA Designated Agent, the agent's current information must be displayed publicly and maintained consistently with the U.S. Copyright Office registration.

45. Registered DMCA Agent status

Unless a dedicated registered-agent block containing current agent details is displayed on this page, Grablex does not represent through this Policy that it currently has an active registered Designated Agent for §512(c)(2).

A general copyright complaint may still be submitted through the contact/reporting process described above.

Where a current registered DMCA Designated Agent is displayed, a person wishing to send a formal §512 notification should use the designated agent contact information shown on this page. Grablex may internally forward a notice received through another channel, but does not represent that delivery to an unrelated address automatically satisfies statutory designated-agent delivery requirements.

45A. Public information for a registered agent

If Grablex activates a registered U.S. DMCA Designated Agent, the public agent information must be kept current and consistent with the Copyright Office designation.

The public information required by the current U.S. regulation includes, as applicable:

• the full legal name of the service provider;
• the service provider's physical street address;
• relevant alternate names used by the service provider, including names/website addresses the public is likely to search;
• the designated agent's name or qualifying position/department/entity;
• the designated agent's physical mail address;
• telephone number;
• and email address.

No registered-agent block is published with invented or stale details.

DMCA TAKEDOWN NOTICE

46. Required DMCA elements

Where a formal U.S. DMCA notice is being submitted under §512(c)(3), it must contain substantially:

1. a physical or electronic signature of the copyright owner or person authorised to act for the owner;
2. identification of the copyrighted work claimed to have been infringed, or a representative list where permitted for multiple works on a single online site;
3. identification of the allegedly infringing material or activity and information reasonably sufficient to permit the service provider to locate it;
4. information reasonably sufficient to contact the complaining party;
5. a statement that the complaining party has a good-faith belief that the complained-of use is not authorised by the copyright owner, its agent, or the law;
6. a statement that the information in the notification is accurate and, under penalty of perjury, that the complaining party is authorised to act on behalf of the owner of an exclusive right allegedly infringed.

47. Signature

A qualifying DMCA notice may use a physical or electronic signature.

The report interface may provide a typed electronic-signature field where legally appropriate.

48. Copyright registration number

A U.S. copyright registration number is not a statutory prerequisite to sending a §512 takedown notice.

A reporter may nevertheless provide registration information as supporting evidence if available.

49. Expeditious action

Where Grablex operates an applicable §512 hosting/search/caching safe-harbor process and receives a sufficiently compliant notice, Grablex acts expeditiously as required by the relevant §512 provision.

The appropriate action depends on Grablex's actual OSP function.

50. User notification

Where §512 requires it, Grablex takes reasonable steps to promptly notify the Customer/user whose material was removed or disabled because of the DMCA notice.

That notice may explain the counter-notification process.

DMCA COUNTER-NOTIFICATION

51. When a counter-notice may be used

A person whose material was removed or disabled under an applicable U.S. DMCA notice-and-takedown process may submit a counter-notification where that person believes removal or disabling resulted from:

• mistake; or
• misidentification of the material.

A DMCA counter-notice is not the appropriate mechanism for every contractual or EU-law restriction.

52. Required counter-notice elements

An effective §512(g) counter-notification must contain substantially:

1. the subscriber's physical or electronic signature;
2. identification of the removed/disabled material and the location at which it appeared before removal/disabling;
3. a statement under penalty of perjury that the subscriber has a good-faith belief that the material was removed or disabled as a result of mistake or misidentification;
4. the subscriber's name, address and telephone number;
5. the required consent to the jurisdiction of the relevant U.S. Federal District Court under §512(g);
6. and a statement that the subscriber will accept service of process from the person who submitted the original notification or that person's agent.

For a subscriber whose address is outside the United States, the statutory jurisdiction statement concerns any judicial district in which the service provider may be found.

53. Counter-notice information is shared with the claimant

The U.S. DMCA counter-notice process requires the service provider to provide the original complaining party with a copy of a compliant counter-notification.

A person submitting a counter-notice should therefore understand that the statutory counter-notice information, which can include:

• name;
• address;
• telephone number;
• statements;
• and signature information

may be disclosed to the original complainant as part of the legal process.

This is separate from ordinary publication of personal data; Grablex does not publish the counter-notice publicly merely because it is submitted.

Where the counter-notifier is in the EEA or another jurisdiction with international-transfer restrictions and the claimant is outside that jurisdiction, Grablex also applies the applicable data-protection and international-transfer rules to the statutory counter-notice process.

10–14 BUSINESS DAY PROCESS

54. Notice to the original claimant

After receipt of a compliant counter-notice in the applicable DMCA process, Grablex promptly provides the original notifying party with:

• a copy of the counter-notice;
• and notice that the removed material will be replaced or access restored according to the statutory timetable unless Grablex receives notice of qualifying court action.

55. Restoration period

Subject to §512(g), Grablex restores the material or ceases disabling access:

not less than 10 and not more than 14 business days

following receipt of a compliant counter-notification,

unless Grablex's designated agent first receives notice from the original notifying party that the party has filed an action seeking a court order to restrain the subscriber from engaging in the alleged infringement.

56. Independent restriction grounds

A DMCA counter-notice does not automatically override a genuinely independent restriction required by:

• another law;
• a valid court/authority order;
• malware/phishing rules;
• another AUP violation;
• another person's rights;
• or a separate contractual ground.

Any independent restriction must be documented and must not be fabricated merely to defeat the DMCA counter-notice process.

DMCA MISREPRESENTATION

57. Accuracy

Persons submitting DMCA notices and counter-notices should provide accurate information.

Under 17 U.S.C. §512(f), certain knowing material misrepresentations concerning infringement or erroneous removal may result in liability for damages, including costs and attorneys' fees.

REPEAT INFRINGEMENT

58. Repeat-infringer policy

Where Grablex seeks the benefit of an applicable §512 safe harbor, Grablex adopts, informs Customers of and reasonably implements a policy providing for termination, in appropriate circumstances, of Customers/users who are repeat infringers.

59. No automatic three-strikes rule

This Policy does not establish that exactly three allegations automatically prove repeat infringement.

Grablex may consider relevant circumstances such as:

• valid takedowns;
• repeated clear infringement;
• own-initiative knowledge;
• retractions;
• restored content;
• successful counter-notices;
• court orders;
• duplicate/abusive notices;
• severity;
• deliberate conduct;
• and other evidence.

A repeat-infringer policy must be genuinely and reasonably implemented rather than being purely nominal.

60. Standard technical measures

Where §512(i) applies, Grablex accommodates and does not interfere with qualifying “standard technical measures” as defined by U.S. copyright law.

This does not mean that every technology proposed by a private claimant automatically qualifies as a statutory standard technical measure.

60A. Other §512 conditions remain applicable

A registered agent, notice-and-takedown form and repeat-infringer policy are not the only conditions relevant to §512 safe harbor.

Depending on the OSP function, additional statutory conditions may include:

• absence of disqualifying actual or “red flag” knowledge;
• expeditious action after obtaining the relevant knowledge;
• for applicable hosting/information-location functions, absence of a direct financial benefit attributable to infringing activity where the provider has the right and ability to control that activity;
• subsection-specific caching conditions;
• and the transmission/conduit conditions applicable to §512(a).

Grablex assesses safe-harbor eligibility separately for each technical function rather than claiming blanket immunity.

NO GENERAL COPYRIGHT MONITORING PROMISE

61. No blanket monitoring promise

Neither this Policy nor the DSA creates a general promise that Grablex manually reviews every Customer file for copyright infringement.

The U.S. DMCA safe-harbor framework likewise does not generally impose an affirmative duty on a qualifying OSP to monitor its service for infringement merely to obtain the safe harbor.

Different obligations may apply if Grablex later qualifies as an EU online content-sharing service provider.

U.S. SUBPOENAS AND COURT ORDERS

62. §512(h) subpoenas

Where a qualifying U.S. §512(h) subpoena or another binding legal order is properly served on Grablex, Grablex verifies the order and handles it according to applicable law.

A request merely labelled “subpoena” is not treated as automatically valid without appropriate verification.

63. Identification information

Where Grablex is legally required to disclose information identifying an alleged infringer under a valid binding process, Grablex may disclose the information within the lawful scope of that process.

The Privacy Policy and applicable legal-request safeguards continue to apply to handling and disclosure.

FUTURE OCSSP RULES

64. OCSSP launch gate

If a future Grablex Service qualifies as an online content-sharing service provider under Directive (EU) 2019/790 and Czech §§46–51, a separate compliance regime becomes applicable.

That regime may require, depending on the circumstances:

• best efforts to obtain authorisation/licences;
• best efforts concerning specifically identified protected works;
• expeditious removal following a sufficiently substantiated rights-holder notice;
• best efforts to prevent re-upload where legally required;
• proportionality;
• information to rights holders;
• information to users;
• complaint/redress;
• protection of lawful exceptions and limitations;
• and other statutory safeguards.

65. No general monitoring under OCSSP law

The application of the OCSSP rules does not create a general monitoring obligation.

Preventive measures must respect the safeguards in applicable EU/Czech law.

66. Lawful user content

For a qualifying OCSSP, cooperation with rights holders must not result in the systematic blocking of lawful user uploads.

Relevant EU rules expressly protect lawful uses, including applicable:

• quotation;
• criticism;
• review;
• caricature;
• parody;
• and pastiche.

67. OCSSP complaint mechanism

For a qualifying OCSSP, Czech law requires an effective and rapid complaint and redress mechanism for users disputing removal/disablement.

That mechanism must be:

• available to affected users;
• handled without undue delay;
• free of charge;
• and not decided exclusively by automated means.

68. New OCSSP regime

Czech law provides a specific proportional regime for qualifying OCSSPs that:

• have been available in the Czech Republic/EU/EEA market for less than three years; and
• have annual turnover below EUR 10 million under the applicable SME calculation.

Where the average monthly number of unique visitors based on the previous calendar year exceeds 5 million, additional best-efforts obligations concerning re-upload prevention apply under Czech law.

Grablex does not apply this regime unless the Service actually qualifies.

PRIVACY AND RECORDS

69. Personal data in copyright complaints

Copyright reports may contain personal data such as:

• claimant name;
• representative;
• email;
• address;
• telephone;
• signature;
• rights documentation;
• Customer identity;
• and correspondence.

Grablex processes such data according to the Privacy Policy and applicable law.

70. Evidence retention

Grablex may retain evidence reasonably necessary for:

• processing the claim;
• defending legal rights;
• DSA records;
• DMCA records;
• repeat-infringer assessment;
• upstream-provider correspondence;
• dispute resolution;
• fraud prevention;
• and legal obligations.

Retention is not unlimited merely because a complaint was submitted.

71. Evidence integrity

Relevant records may include:

• original complaint;
• timestamp;
• exact URL/resource;
• attached evidence;
• Customer mapping;
• decision;
• statement of reasons;
• Customer response;
• counter-notice;
• claimant response;
• restoration;
• upstream correspondence;
• and court/authority process.

CONTACT

72. Current copyright contact

Copyright and intellectual-property reports may currently be sent to:

contact@grablex.com

For best processing, use a clear subject such as:

Copyright Report — [domain or URL]

73. Dedicated reporting system

Where Grablex activates a dedicated reporting system, the Legal Hub or this Policy will identify the current route.

The intended architecture is an electronic:

Copyright / Intellectual Property Report

within the Grablex abuse-reporting system.

CHANGES

74. Changes to this Policy

Grablex may update this Policy when:

• copyright law changes;
• Grablex launches hosting/content-sharing Services;
• the DSA classification changes;
• a U.S. DMCA Designated Agent is registered or changed;
• provider relationships change;
• or new dispute procedures apply.

The current review date is shown at the top.

APPENDIX A — COPYRIGHT NOTICE CHECKLIST

An ordinary copyright report should provide:

```text Rights holder: Authorised representative: Contact email:

Protected work: Original/source reference: Rights/evidence:

Exact alleged infringing URL(s): Why use is alleged to be unlawful:

Good-faith declaration: Accuracy declaration:

Supporting files/evidence: ```

Where a formal U.S. DMCA notice is used, the §512 statutory elements also apply.

APPENDIX B — DMCA NOTICE CHECKLIST

```text [ ] Physical/electronic signature [ ] Copyright owner / authorised agent [ ] Identification of copyrighted work [ ] Representative list where applicable [ ] Exact infringing material/location [ ] Contact information [ ] Good-faith belief statement [ ] Accuracy statement [ ] Authority statement under penalty of perjury ```

APPENDIX C — DMCA COUNTER-NOTICE CHECKLIST

```text [ ] Physical/electronic signature [ ] Removed/disabled material identified [ ] Previous location [ ] Good-faith mistake/misidentification statement under penalty of perjury [ ] Name [ ] Address [ ] Telephone [ ] Federal District Court jurisdiction consent required by §512(g) [ ] Agreement to accept service of process ```

APPENDIX D — DIFFERENT CLAIM TYPES

Effective / review date: 30 August 2026