Gnammus Moderation Policy

Last updated: 21 October 2026

Preamble

This Content Moderation Policy ("Policy") constitutes an Appendix to the Gnammus Terms and Conditions, hereinafter the "General Terms", and sets out the community rules governing the publication of content on the Platform.

Matters not expressly governed by this Policy shall be governed by the General Terms.

Gnammus is a service of:

RTLP S.r.l. — Corte dei Mesagnesi 30 — 73100 Lecce (LE) — Italia

VAT number and tax code: 02683850743 — REA: LE-361688

Gnammus is a social networking platform that enables anyone to share content, ideas and thoughts. RTLP is committed to providing a high-quality and secure Service that fosters digital connections by breaking down geographical, linguistic and cultural barriers, in compliance with applicable legislation and with particular attention to privacy and freedom of expression.

Art. 1 — Moderation principles

1.1. No ideological or editorial censorship. RTLP opposes any form of ideological censorship. Content moderation is not based on judgements of merit, quality or personal taste on the part of RTLP: the sole role of moderation is to prevent the publication of content that infringes applicable law or the rules laid down in this Policy and in the General Terms.

1.2. Moderation tools. The Platform uses both human moderators and automated algorithms to prevent the publication of content that does not comply with the rules of this Policy. RTLP does not guarantee that the moderation systems are infallible or 100% effective: automated and manual moderation may occasionally produce errors, either by preventing the publication of compliant content or by failing to detect non-compliant content. If the User considers that content has been moderated in error, the User may request a review of the decision in accordance with Art. 14. The processing of personal data connected with the use of automated systems is described in Art. 15 of the Privacy Policy.

1.3. Scope. Content moderation applies to content which the User has requested to be published, both before publication and after it in accordance with Art. 13.3. No own-initiative action or check is carried out on content of any kind whose publication has not been requested by the User, such as the Private Content referred to in Art. 7.2 of the Privacy Policy. This is without prejudice to RTLP's right to take action on any content pursuant to an order of the competent authority or following a notice submitted under Art. 12.

1.4. Applicable law. This Policy is subject to Italian national legislation and the related case law, to European Union legislation and, where applicable, to the local laws of the User's country of residence.

1.5. Responsibility of the User. Regardless of the operation of the Platform's moderation systems, the User remains in all cases responsible for the content they publish and for compliance with the laws applicable in their jurisdiction. The existence of moderation systems does not release the User from the obligation to verify that their content complies with the legislation in force and with this Policy.

1.6. Reporting errors. RTLP invites Users to report content that they consider not to comply with this Policy and that has not been detected by the moderation systems, in accordance with Art. 12, and to request a review of content that they consider to have been moderated in error, in accordance with Art. 14. Reports from Users contribute to the continuous improvement of the moderation systems.

Art. 2 — Content that infringes applicable laws or regulations

2.1. Users are required to comply with all applicable laws and regulations when using the Platform, including regional, national and international legislation.

2.2. The User is responsible for complying with local laws and regulations, including any restrictions on specific types of content and the limits on what may or may not be shared or sold in their jurisdiction.

Art. 3 — Incitement to hatred and discrimination

3.1. It is prohibited to share, sell or promote content that includes incitement to hatred, threats or harassment against individuals or groups on the basis of ethnicity, race, national origin, gender, gender identity, sexual orientation, religion, age or disability.

3.2. The prohibition extends to any offensive language, content or behaviour that creates a demeaning or hostile environment.

Art. 4 — Sexually explicit content and protection of minors

4.1. RTLP is committed to creating a safe environment for all Users, including minors.

4.2. It is prohibited to publish content that includes explicit nudity, pornography or other sexually explicit material, including images, videos or discussions of an explicitly sexual nature. RTLP reserves the right to take action on any content reported as inappropriate.

4.3. Any content that is inappropriate, sexually explicit or harmful to minors is strictly prohibited. The distribution of child sexual abuse material (CSAM) or of any material that depicts or justifies the exploitation of minors is also prohibited. Such infringements will result in the immediate suspension of the account, the removal of the content and a report to the competent authorities.

4.4. RTLP reserves the right to take any further measures deemed necessary to protect minors and the safety of Users.

Art. 5 — Violence and content that promotes or glorifies violence

5.1. The sharing of content depicting real violence, acts of cruelty, assaults, attacks, graphic images of death or injury, or terrorist or violent extremist propaganda is prohibited.

5.2. The sharing of content showing vandalism, cruelty or gratuitous violence towards animals is also prohibited.

Art. 6 — Content dangerous to health and misleading information

6.1. It is prohibited to share or promote false or misleading information capable of endangering the health or physical safety of persons or of undermining public security. The prohibition extends to content created by means of deepfakes, generated by artificial intelligence or otherwise manipulated which, by realistically depicting persons, events or places, is capable of deceiving the public and harming individuals or communities.

6.2. It is prohibited to publish content that may prove dangerous to the health or physical safety of persons, including content that promotes, suggests or describes dietary practices, preparations, combinations of ingredients or dosages that could reasonably entail health risks. It is understood that the assessment of dangerousness is not based on judgements of taste or food preference, but exclusively on objective safety criteria.

6.3. Medical, nutritional and therapeutic advice. It is prohibited to publish content which, presented as advice of a medical, nutritional or therapeutic nature, is capable of leading to behaviour harmful to health. The prohibition includes, by way of non-exhaustive example:

the promotion of highly restrictive diets, prolonged fasting or purging or compensatory practices;
the attribution to foods, beverages or food supplements of curative, preventive or slimming properties not permitted by the applicable legislation on nutrition and health claims;
the recommendation to suspend, refuse or replace medical treatment;
the offering of individual prescriptions or diet plans by persons who do not hold the qualifications required by applicable legislation.

6.4. The prohibitions in Art. 6.3 do not cover the sharing of personal experiences, the dissemination of general nutritional content or informative or scientific debate, provided that these are not presented as a prescription addressed to a specific individual.

6.5. Consistently with Art. 1.1, RTLP does not verify the truthfulness of content published by Users, nor does it express any view on its scientific accuracy or its soundness. The assessment under this Article is confined to content that presents a concrete risk to the health or physical safety of persons.

Art. 7 — Infringement of privacy and intellectual property

7.1. It is not permitted to share or promote content that infringes the privacy or personality rights of third parties, including the unauthorised disclosure of private information or sensitive data without the explicit consent of the data subject.

7.2. The sharing or sale of content that infringes intellectual property rights, including copyright, trade marks and patents, without the necessary authorisation is prohibited.

Art. 8 — Self-harm and suicide

8.1. It is prohibited to share or promote content that encourages or facilitates self-harm or suicide, including content relating to eating disorders, extreme diets or the use of dangerous substances.

8.2. Anyone in a crisis situation is encouraged to contact the support resources available in their country. A free, up-to-date list of active helplines, searchable by country, is available at https://findahelpline.com.

Art. 9 — Impersonation

9.1. It is prohibited to impersonate other persons or organisations, including by creating false profiles or content for deceptive or harmful purposes.

Art. 10 — Content subject to geographical or age restrictions

10.1. Certain content, although lawful and compliant with this Policy and the General Terms, may be subject to legal or regulatory restrictions in certain jurisdictions. By way of non-exhaustive example:

content relating to alcoholic beverages in countries where the promotion or depiction of alcohol is prohibited or restricted by law;
content relating to specific foods or ingredients whose marketing or promotion is regulated locally;
content which, although lawful in the country of publication, may conflict with the local legislation of other countries.

10.2. In such cases, RTLP reserves the right to restrict the visibility of such content in the jurisdictions concerned, without removing it from the Platform.

10.3. RTLP does not guarantee that geographical filters are 100% effective in blocking the display of restricted content in every jurisdiction. The User remains in all cases responsible for complying with the laws applicable in their country of residence, regardless of the visibility of content on the Platform. The User is invited to report to RTLP any content which they consider should not be visible in their jurisdiction, using the Platform's reporting tools.

10.4. Such restrictions do not constitute a judgement by RTLP on the merits of the content, but solely represent compliance with local regulatory obligations. The content remains fully visible in the jurisdictions where no restrictions apply.

10.5. The list of active geographical restrictions is subject to periodic updating by RTLP in line with developments in the applicable legislation.

10.6. Content relating to alcoholic beverages. The minimum age for access to the Platform is laid down in Art. 3.1 of the General Terms. The age restriction provided for in this Article applies to content whose subject matter is alcoholic beverages as such, namely content that depicts or promotes them or describes their characteristics, consumption, tasting or pairing. Such content is visible only to Users who have reached the higher of the age of 18 and the minimum age laid down by the law of their country of residence for the purchase or consumption of alcoholic beverages; where that law lays down different ages depending on the beverage, the lowest shall be taken into account. Age is determined on the basis of the date of birth and the country of residence declared by the User at registration. Users resident in countries in which alcoholic beverages are prohibited cannot see such content, pursuant to Art. 10.2, except for content they have published themselves. The thresholds applied by RTLP reflect the legislation in force in the individual countries and are subject to updating should that legislation change. This restriction applies in addition to the geographical restrictions referred to in the preceding paragraphs.

10.7. Alcoholic beverages as ingredients. The restriction in Art. 10.6 does not cover content in which an alcoholic beverage appears as an ingredient of a food preparation, even where it is mentioned in the list of ingredients, in the method of preparation or in the name of the recipe. Such content may be published by any User and is visible to all Users. The exclusion does not apply where the content, although presented as a food preparation, in fact has the purpose of promoting an alcoholic beverage or encourages its consumption.

10.8. Publication by Users who have not reached the required age. A User who has not reached the age referred to in Art. 10.6 may publish the content referred to in that provision. Such content is visible to Users who have reached the age referred to in Art. 10.6 and to the User who published it, and is not visible to other Users. The age restriction therefore does not apply to the author of the content, who in all cases retains access to their own content and to the functions needed to view, edit or remove it. However, a User under the age of 18 is prohibited from publishing content promoting alcoholic beverages for the benefit of a third party within the meaning of Art. 11.5, even if the User declares its commercial nature and even if the content is made visible only to Users who have reached the age referred to in Art. 10.6.

10.9. Labelling of content. RTLP identifies and labels content relating to alcoholic beverages by means of its own automated classification systems. The obligation to label such content in advance, using the tools made available by the Platform, rests solely with Users acting for purposes relating to their trade, business, craft or profession — such as producers, distributors, retailers and agencies — and only in respect of sponsored, advertising or otherwise promotional content. A User who declares the commercial nature of the content under Art. 11.5 and indicates that it concerns alcoholic beverages thereby fulfils the obligation laid down in this paragraph. This is without prejudice to RTLP's right to apply the age restriction on its own initiative to any content found to lack such labelling.

10.10. RTLP reserves the right to extend the age restriction to other categories of content where this is required by applicable legislation or is necessary to protect minors. The provisions of Art. 1.2 on the fallibility of moderation systems and of Art. 10.3 on the responsibility of the User also apply to age restrictions.

Art. 11 — Commercial communications: prohibited advertising and duty to declare

11.1. Advertising, promotion and sponsorship, in any form, direct or indirect, of tobacco products and related products are prohibited. The prohibition includes, by way of non-exhaustive example:

cigarettes, cigars, cigarillos, roll-your-own tobacco, pipe tobacco, nasal tobacco and chewing tobacco;
heated tobacco products;
electronic cigarettes, vaping devices and refill containers, with or without nicotine;
nicotine products not intended for therapeutic use, such as oral nicotine pouches;
herbal products for smoking;
accessories, trade marks and distinctive signs used to promote the products listed above.

11.2. The prohibition in Art. 11.1 applies across the entire Platform and in all jurisdictions, irrespective of whether advertising of such products is permitted in the country of residence of the User publishing the content or in that of the recipient. It applies both to sponsored content and to content published by Users acting for purposes relating to their trade, business, craft or profession.

11.3. The prohibitions laid down in this Article concern promotion, not depiction. They therefore do not cover the incidental depiction of the products and services to which they refer within content that has no promotional purpose, nor the dissemination of informative, journalistic, scientific, educational or prevention-related content, nor an account of a personal experience. RTLP may nevertheless apply the age restriction referred to in Art. 10.10 to such content.

11.4. Advertising, promotion, sponsorship and sale, in any form, direct or indirect, of the following products and services are also prohibited:

narcotic drugs and psychotropic substances, as well as products the marketing of which is prohibited by applicable legislation;
games with cash prizes, betting, pools and any other form of gambling, including the trade marks and business signs of the relevant operators, referral codes, sign-up bonuses and links to the relevant platforms;
weapons, ammunition, their parts and components, explosives and other offensive instruments, as well as dangerous substances and materials the use of which requires a qualification or an authorisation;
medicinal products and products presented as having properties for preventing, treating or curing diseases;
financial, insurance and investment products and services, crypto-assets and trading, custody or brokerage services in respect of them, including the training courses, trading signals and affiliate programmes relating to them;
cosmetic surgery and invasive medical or aesthetic treatments, including injectable treatments and procedures involving anaesthesia.

The exclusion referred to in Art. 11.3 applies to the prohibitions laid down in this paragraph. Nor does the prohibition cover the indication of the activity carried out and the services offered by an account identified on the Platform as a trade, business, craft or professional activity, where that indication is informative rather than promotional in nature.

11.5. Duty to declare the commercial nature of content. A User who publishes content with a promotional purpose for the benefit of a third party, in return for payment or any other benefit, is required to declare its commercial nature using the dedicated functionality made available by the Platform when creating the content. The obligation applies irrespective of whether the promotional agreement was concluded through RTLP's advertising services or directly between the User and the third party concerned, and irrespective of the form of the benefit received. This includes in particular:

the payment of a sum of money or the granting of remuneration in any other form;
the provision, free of charge or on preferential terms, of products, services, hospitality, travel or experiences;
the granting of a commission or an economic advantage linked to the sales or visits generated by the content, including through affiliate links or personalised discount codes;
the inclusion of products, trade marks, business signs or other distinctive signs of third parties in performance of an agreement, even if not in writing, with their owner.

11.6. Method of declaration. The declaration is made exclusively by means of the dedicated functionality referred to in Art. 11.5, following which RTLP places on the content, in a visible and recognisable manner, an indication of its commercial nature. Inserting indications in the text, description, comments or tags associated with the content does not replace the declaration and is not in itself sufficient to fulfil the obligation.

11.7. Excluded cases. The obligation in Art. 11.5 does not apply to content whose commercial purpose is already evident from the context, such as content relating to one's own products, services or establishments and published by an account identified on the Platform as a trade, business, craft or professional activity. Nor does it cover the mention or depiction of products, trade marks or establishments of third parties in the absence of any agreement and of any benefit, such as the indication of an ingredient used in a preparation or an account of an experience paid for at one's own expense.

11.8. Responsibility for the declaration. The declaration referred to in Art. 11.5 is made by the User under their own responsibility. RTLP is not in a position to know or verify promotional agreements concluded outside its own advertising services and is not liable for any failure to declare or any inaccurate declaration. Under the applicable legislation on unfair commercial practices, the obligation to make the promotional purpose of content recognisable rests with the User acting for purposes relating to their trade, business, craft or profession and with the person in whose interest the promotion is carried out. This is without prejudice to RTLP's right to place, on its own initiative, the indication referred to in Art. 11.6 on content that lacks it and that contains elements giving reason to presume its commercial nature.

11.9. Promotional content relating to alcoholic beverages. Content promoting alcoholic beverages, in addition to being subject to the age restriction referred to in Art. 10.6 and to the duty to declare referred to in Art. 11.5, must not:

be aimed specifically at minors, or depict minors consuming alcoholic beverages;
encourage excessive or immoderate consumption of alcoholic beverages, or present abstinence in a negative light;
link the consumption of alcoholic beverages to driving vehicles or to enhanced physical performance;
create the impression that the consumption of alcoholic beverages contributes towards social or sexual success;
claim that alcoholic beverages have therapeutic, stimulant or sedative qualities, or that they are a means of resolving conflicts or personal distress.

This is without prejudice to the prohibition, laid down in Art. 10.8, on Users under the age of 18 publishing content promoting alcoholic beverages. Compliance with the requirements of this paragraph is the responsibility of the User publishing the content and of the person in whose interest the promotion is carried out. RTLP does not carry out prior checks on the age of persons depicted in content and does not use facial recognition or age estimation systems for that purpose; it takes action, by means of the measures referred to in Art. 13, against content found to be non-compliant following a notice submitted under Art. 12 or a finding made by any other means.

11.10. Undeclared promotional content. Failure to declare the commercial nature of content constitutes a breach of this Policy and entitles RTLP to adopt the measures referred to in Art. 13. Where the content concerns alcoholic beverages, the age restriction referred to in Art. 10.6 applies in all cases, even in the absence of a declaration.

Art. 12 — Reporting of content

12.1. Reporting tools. Anyone — whether a User or a third party — may notify RTLP of content on the Platform that they consider to be illegal or not to comply with this Policy, using the reporting functions available within the Platform or the contact details set out in Art. 16 of the General Terms. The reporting tools are easy to access and user-friendly and allow notices to be submitted by electronic means.

12.2. Content of the notice. Pursuant to Article 16 of Regulation (EU) 2022/2065, the notice should contain:

a sufficiently substantiated explanation of the reasons why the content is considered to be illegal or non-compliant;
a precise indication of the location of the content, such as the exact URL or URLs;
the name and email address of the notifier, except where the notice concerns the offences referred to in Articles 3 to 7 of Directive 2011/93/EU;
a statement confirming the bona fide belief of the notifier that the information and allegations contained in the notice are accurate and complete.

12.3. Confirmation of receipt. RTLP sends, without undue delay, a confirmation of receipt of the notice to any notifier who has provided an email address.

12.4. Processing of notices. RTLP processes notices in a timely, diligent, non-arbitrary and objective manner. RTLP determines the appropriate measures and, where it considers it necessary, informs the notifier accordingly.

12.5. Manifestly unfounded notices. RTLP may suspend, after issuing a prior warning and for a reasonable period of time, the processing of notices submitted by individuals or entities that frequently submit manifestly unfounded notices.

Art. 13 — Available measures and statement of reasons

13.1. Measures concerning content. In the event of an infringement of this Policy, the General Terms or applicable law, RTLP may, depending on the seriousness, repetition and nature of the infringement, adopt one or more of the following measures:

refusal to publish the content;
removal of content already published;
restriction of the visibility of the content, including on a geographical or age basis;
the application of a warning or of an access restriction to the content.

13.2. Measures concerning the account. In the most serious cases or in the event of repeated infringements, RTLP may adopt the following measures against the User, on a graduated basis: a warning; the temporary restriction of certain functionalities; suspension of the account; deletion of the account pursuant to Art. 3.8 of the General Terms.

13.3. Post-publication moderation. The measures referred to in Art. 13.1 may also be adopted in respect of content already published, where non-compliance subsequently emerges following a notice, an own-initiative investigation, a change in the applicable legislation or an order of the competent authority. The publication of content does not constitute approval by RTLP or a definitive finding that it is compliant.

13.4. Statement of reasons. Each measure adopted under Arts. 13.1 and 13.2 is communicated to the User concerned, unless such communication is prohibited by law or by an order of the competent authority. The communication sets out:

the measure adopted, its territorial scope and its duration;
the facts and circumstances relied on in taking the decision, including information on whether it was taken following a notice submitted under Art. 12 or on the basis of an own-initiative investigation;
whether and to what extent automated means were used in taking the decision, including where the content was detected automatically;
the provision of this Policy, the General Terms or the law on which the decision is based;
the means of, and time limits for, requesting a review of the decision under Art. 14.

13.5. Urgent measures. In the cases referred to in Art. 4.3 and in other cases of serious and present danger to the safety of persons, RTLP adopts the necessary measures with immediate effect, providing the statement of reasons referred to in Art. 13.4 after their adoption.

Art. 14 — Complaints and review of decisions

14.1. Right to a review. The User subject to a measure referred to in Art. 13, as well as the notifier who has received the communication referred to in Art. 12.4, may request that RTLP review the decision, using the tools available within the Platform or the contact details set out in Art. 16 of the General Terms.

14.2. Time limit for complaints. A complaint may be lodged within 14 days of notification of the decision. In the event of suspension of the account, the account remains suspended for the duration of that time limit and until the complaint has been decided. If no complaint is lodged within the time limit, the measure shall be deemed final.

14.3. Examination of complaints. Complaints are examined by RTLP staff and are in no case decided solely on the basis of automated means. RTLP communicates the outcome of the review, with adequate reasons, without undue delay.

14.4. Effects. Where the review establishes that the measure was unfounded, RTLP reverses it without delay and restores, where technically possible, the content or functionalities concerned. The provisions of Art. 7.4 of the Privacy Policy on technical implementation times apply.

14.5. Other means of redress. The review under this Article is without prejudice to the User's right to bring proceedings before the competent court pursuant to Art. 19 of the General Terms or, for a User acting as a Consumer, to have recourse to the out-of-court dispute settlement procedures referred to in Art. 20.2(c) of those Terms. The right to lodge a complaint with the competent data protection supervisory authority, as provided for in Art. 12 of the Privacy Policy, is likewise unaffected.

Art. 15 — Breach of the General Terms

15.1. Users are required to comply with the General Terms and all applicable Appendices. Content that breaches those provisions will be removed, and further measures may be adopted against the User under Art. 13.

15.2. Spam and flooding. The serial, automated or mass publication or sending of content, comments, messages or reports, as well as any conduct that floods the Platform, constitutes a breach of Art. 7 of the General Terms and of this Policy. RTLP may adopt the measures referred to in Art. 13.

Art. 16 — Amendments and cross-reference

16.1. This Policy may be amended to adapt to social, technological and regulatory changes. In such case, the provisions on amendments to the Terms contained in the General Terms apply.

16.2. Matters not expressly governed by this Policy shall be governed by the General Terms.