Content Moderation and Copyright Policy

Part A: Content Moderation

1. Nature of the Service

1.1SphereOne is a private business collaboration platform. Content is shared within Workspaces controlled by our business Customers and is not published to the general public. Each Customer is responsible for the content its Users create and share, and for moderating its own Workspace in accordance with its internal policies.

1.2Altrivis Management LLC ("Altrivis", "we" or "us") does not proactively monitor or review Customer content, and does not use automated classifiers to screen it. We act on reports, on legal requests, and where we otherwise obtain knowledge of unlawful content or activity.

2. Reporting Content

2.1Anyone may report content or conduct that they believe breaches our Acceptable Use Policy or the law by writing to support@sphereone.ai. Reports should identify the Workspace or User concerned (where known), describe the content or conduct, and explain why it is considered unlawful or in breach.

2.2We will acknowledge reports within two (2) business days and assess them diligently and objectively.

3. Our Response

3.1Because content belongs to our Customers, we will ordinarily first refer a report to the Customer's Administrator and ask the Customer to take appropriate action.

3.2We may act directly, including by removing or disabling access to content, or suspending a User or Workspace, where: (a) the content is clearly unlawful; (b) the Customer does not take appropriate action within a reasonable time; (c) there is a risk of serious harm to any person; (d) the content threatens the security or integrity of the Services; or (e) we are required to do so by law or court order.

3.3Our measures are proportionate to the seriousness of the breach, and may range from a warning, to removal of specific content, to suspension or termination of Users or accounts.

3.4Where we remove content or restrict an account, we will inform the affected Customer of the action and the reason, unless prohibited by law or where notice would risk harm or compromise an investigation. The Customer may ask us to review the decision by writing to support@sphereone.ai, and a person not involved in the original decision will consider the request.

4. Child Safety

4.1We have zero tolerance for child sexual abuse material. Where we obtain actual knowledge of apparent child sexual abuse material on the Services, we will disable access to it, preserve it as required by law, report it to the National Center for Missing and Exploited Children in accordance with 18 U.S.C. § 2258A, and terminate the accounts involved.

5. Requests from Government and Law Enforcement

5.1We disclose Customer Data to government or law enforcement authorities only in response to valid legal process, such as a subpoena, court order or search warrant, issued by an authority with jurisdiction over Altrivis, or in an emergency involving imminent risk of death or serious physical injury.

5.2We review every request for legal validity and scope, and we challenge requests that are overbroad or unlawful. Where possible, we redirect authorities to request data directly from the Customer.

5.3Unless legally prohibited, we notify the affected Customer before disclosing its data, so that it may seek a protective order or other remedy.

5.4Requests should be sent to support@sphereone.ai, or served on our registered agent at 5900 Balcones Drive, Suite 100, Austin, Texas 78731.

6. European Union

6.1Where the EU Digital Services Act applies to us as a provider of hosting services, our point of contact for authorities and recipients of the service is support@sphereone.ai, and we accept communications in English. Notices of illegal content may be sent to support@sphereone.ai and will be processed in accordance with Article 16 of that Act, with statements of reasons provided to affected Users under Article 17.

Part B: Copyright and the Digital Millennium Copyright Act

7. Policy

7.1We respect the intellectual property rights of others and expect our Users to do the same. We respond to notices of alleged copyright infringement that comply with the Digital Millennium Copyright Act, 17 U.S.C. § 512 (the "DMCA").

8. Designated Agent

8.1Our designated agent to receive notices of claimed infringement is:

9. Notice of Claimed Infringement

9.1To be effective, a notice must be in writing, sent to the designated agent, and include substantially the following:

• (a)a physical or electronic signature of a person authorised to act on behalf of the owner of the copyright allegedly infringed;
• (b)identification of the copyrighted work claimed to have been infringed or, if multiple works are covered by a single notice, a representative list;
• (c)identification of the material claimed to be infringing, with information reasonably sufficient to permit us to locate it;
• (d)the complaining party's name, address, telephone number and email address;
• (e)a statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorised by the copyright owner, its agent or the law; and
• (f)a statement that the information in the notice is accurate and, under penalty of perjury, that the complaining party is authorised to act on behalf of the copyright owner.

9.2On receiving a compliant notice, we will expeditiously remove or disable access to the material and notify the User who posted it and the Customer's Administrator.

9.3A person who knowingly materially misrepresents that material is infringing may be liable for damages under 17 U.S.C. § 512(f).

10. Counter-notification

10.1A User whose material has been removed may send a counter-notification to the designated agent, which must include:

• (a)the User's physical or electronic signature;
• (b)identification of the material removed and the location at which it appeared before removal;
• (c)a statement under penalty of perjury that the User has a good faith belief that the material was removed or disabled as a result of mistake or misidentification;
• (d)the User's name, address and telephone number, and a statement that the User consents to the jurisdiction of the federal district court for the judicial district in which the User's address is located (or, if outside the United States, any judicial district in which Altrivis may be found), and will accept service of process from the person who provided the original notice or that person's agent.

10.2On receiving a valid counter-notification, we will send a copy to the complaining party and restore the material not less than ten (10) and not more than fourteen (14) business days after receipt, unless the complaining party notifies us that it has filed an action seeking a court order against the User.

11. Repeat Infringers

11.1We will terminate, in appropriate circumstances, the accounts of Users who are repeat infringers. A User who is the subject of three (3) valid notices that are not successfully countered within a twelve (12) month period will ordinarily be treated as a repeat infringer.

12. Other Intellectual Property

12.1Complaints about trade mark or other intellectual property infringement may be sent to support@sphereone.ai and will be handled under Part A of this Policy.