Moderation and Enforcement policy

1. Our Approach

Reineur uses moderation to enforce its Terms of Use, Acceptable Use Policy and Community Guidelines, and other applicable policies while maintaining a safe, useful, and respectful platform.

Reports may be reviewed by authorised Community moderators or Reineur's Trust & Safety team, depending on the nature, severity, and scope of the issue.

Reineur aims to apply its rules consistently, fairly, and proportionately, taking into account the circumstances of each case and applicable Nigerian law.

2. What We May Take Action Against

Reineur may take action against content, accounts, Communities, or behaviour that violates:

2.1. The Terms of Use.

2.2. The Acceptable Use Policy and Community Guidelines.

2.3. Other Reineur policies.

2.4. Applicable Nigerian law or other applicable law.

This may include spam, harassment, bullying, hate speech, impersonation, privacy violations, fraud, threats, child safety violations, sexual exploitation, intellectual property infringement, security abuse, and other prohibited conduct.

3. Reporting

Users may report content, accounts, Communities, or behaviour through Reineur's reporting tools or by contacting info@reineur.com

When reviewing a report, Reineur may consider:

3.1. The reported content or behaviour.

3.2. Relevant context and available evidence.

3.3. The severity and potential harm.

3.4. Whether the conduct is ongoing or presents an immediate risk.

3.5. Previous or repeated violations.

3.6. Applicable Reineur policies or law.

The number of reports does not determine whether a violation occurred. Multiple reports concerning the same issue may be combined into a single moderation case.

Submitting a report does not guarantee enforcement action.

4. Who Handles Reports

Community-level issues may be handled by Community owner and admins.

Serious, complex, repeated, cross-Community, or platform-wide issues may be handled by Reineur's Trust & Safety team.

Reineur may escalate, transfer, or take over any moderation matter where appropriate.

Community admins must not handle matters involving a conflict of interest or their own conduct.

5. Reporter Privacy

Reineur will seek to protect the identity and personal information of Users who submit reports.

Reineur will not ordinarily disclose a reporter's identity to the reported User or Community moderators, except where permitted or required by law or where disclosure is necessary for a legitimate moderation, safety, legal, or regulatory purpose.

Authorised Reineur personnel may access information relating to reports where reasonably necessary to investigate and resolve a matter.

Certain legal complaints, including intellectual property complaints, may have different information-sharing requirements.

Our Privacy Policy explains how Reineur handles personal data relating to reports, investigations, and moderation.

6. Enforcement Actions

Depending on the circumstances, Reineur may:

6.1. Take no action.

6.2. Issue a warning or educational notice.

6.3. Request changes to content.

6.4. Remove or restrict content.

6.5. Limit or disable specific platform features.

6.6. Restrict or remove Community content.

6.7. Restrict moderation or Community management privileges.

6.8. Temporarily suspend an account or Community.

6.9. Permanently terminate an account or Community.

Reineur may apply more than one enforcement action where appropriate.

The action taken may depend on the nature, severity, frequency, and potential impact of the violation.

7. Serious or Urgent Violations

Reineur may take immediate action without issuing a warning where necessary to protect Users, the Services, or comply with applicable law.

This may include serious threats, child safety violations, sexual exploitation, significant fraud, serious security risks, credible risks of harm, or other severe violations.

Actions may include:

7.1. Removing or restricting content.

7.2. Restricting access to features or Communities.

7.3. Suspending an account.

7.4. Permanently terminating an account.

Where required or permitted by applicable Nigerian law, Reineur may preserve relevant information and notify or cooperate with law enforcement, regulatory authorities, or other competent authorities.

8. Repeat Violations and Enforcement Evasion

Repeated violations may result in stronger enforcement.

Reineur may consider the nature, severity, frequency, and pattern of violations when determining an appropriate action.

Users must not evade enforcement by:

8.1. Creating or using another account to circumvent a restriction or suspension.

8.2. Circumventing technical or account restrictions.

8.3. Using another person's account to avoid enforcement.

8.4. Coordinating with others to bypass an enforcement measure.

There is no fixed number of warnings required before enforcement.

Serious violations may result in immediate suspension or permanent termination.

9. Content That Is Edited or Deleted

Editing or deleting reported content does not necessarily end a moderation review.

Reineur may consider previous versions of content where reasonably available and may retain relevant information where necessary for:

9.1. Moderation and enforcement.

9.2. Appeals.

9.3. User safety.

9.4. Security and fraud prevention.

9.5. Legal or regulatory compliance.

9.6. Establishing, exercising, or defending legal claims.

Information retained for these purposes will be handled in accordance with Reineur's Privacy Policy and applicable law.

10. Appeals

Users may appeal eligible enforcement decisions through the process provided by Reineur.

Appeals should explain why the decision was incorrect and may include relevant information or evidence.

Where reasonably possible, appeals will be reviewed separately from the original decision.

An appeal may result in a decision being:

10.1. Upheld.

10.2. Modified.

10.3. Reversed.

Some decisions may not be eligible for appeal where legal, safety, security, or other legitimate considerations apply.

11. Malicious Reporting

Reporting tools must not be used to:

11.1. Harass, threaten, or retaliate against Users.

11.2. Submit knowingly false or misleading reports.

11.3. Coordinate reports to manipulate moderation outcomes.

11.4. Repeatedly report content without a legitimate basis.

Good-faith reports that do not result in enforcement are not, by themselves, a violation.

Abuse of reporting tools may result in enforcement action.

12. Legal and Emergency Requests

Reineur may remove, restrict, preserve, or disclose information where required or permitted by applicable law.

This may include responding to:

12.1. Valid court orders.

12.2. Lawful requests from law enforcement authorities.

12.3. Lawful requests from regulatory authorities.

12.4. Intellectual property or copyright complaints.

12.5. Valid legal processes.

12.6. Emergencies involving serious and credible risks to safety or harm.

Reineur will assess requests as appropriate and may require valid legal authority before disclosing information where applicable.

Where legally permitted, Reineur may notify affected Users about relevant requests or actions.

13. Moderation Systems

Reineur may use automated systems, human review, or a combination of both to detect, prioritise, investigate, and enforce policy violations.

Automated systems may assist with detecting spam, fraud, abuse, security threats, and other potentially prohibited activity.

Automated systems may also be used to prioritise reports for human review.

Where appropriate, Reineur may conduct additional human review or provide an appeal process for enforcement decisions.

14. Moderation Records

Reineur may retain information relating to reports, investigations, enforcement decisions, and appeals where reasonably necessary for:

14.1. User safety.

14.2. Security and fraud prevention.

14.3. Enforcement of Reineur policies.

14.4. Legal or regulatory compliance.

14.5. Dispute resolution.

14.6. Establishing, exercising, or defending legal claims.

14.7. Preventing repeated violations or enforcement evasion.

Access to moderation information is limited to authorised personnel or service providers who require access for the relevant purpose.

Moderation information will be handled in accordance with Reineur's Privacy Policy and applicable Nigerian data-protection requirements.

15. Fair and Proportionate Enforcement

Reineur aims to apply enforcement measures proportionately to the circumstances of each case.

When determining an appropriate action, Reineur may consider:

15.1. The seriousness of the violation.

15.2. The potential or actual harm caused.

15.3. Whether the conduct was intentional or repeated.

15.4. The User's previous enforcement history.

15.5. Whether the User cooperated with the moderation process.

15.6. Whether immediate action is necessary to protect Users, the platform, or other persons.

Nothing in this section requires Reineur to use progressive enforcement where immediate action is reasonably necessary.

16. No Guarantee of Enforcement

Reineur cannot guarantee that every violation will be identified, reported, investigated, or acted upon.

The absence of enforcement against particular content or behaviour does not mean that the content or behaviour is permitted.

Reineur may take action when additional information becomes available or when circumstances change.

17. Compliance With Nigerian Law

Reineur operates its moderation and enforcement processes in accordance with applicable Nigerian law.

Nothing in this Policy limits Reineur's ability to take lawful action to protect Users, the Service, its rights, or the rights of others.

Where applicable, Reineur will consider relevant requirements relating to privacy and personal data protection, lawful requests from competent authorities, intellectual property, child safety, cybersecurity, and other applicable Nigerian legal and regulatory requirements.

Where a conflict arises between this Policy and a mandatory legal requirement, the applicable legal requirement will apply.

18. Changes to This Policy

We may update this Policy when our Services, moderation practices, technology, or legal obligations change.

Where required, material changes will be communicated through the app, email, or other appropriate channels.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised.

19. Contact

If you have questions about this Moderation and Enforcement policy, contact us at:

Reineur Limited

Email: privacy@reineur.com

Address: Plot 76A Fiditi Avenue, Off Ordinance Road, Trans Amadi Industrial Layout, Port Harcourt, Rivers State, Nigeria.

If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.