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Acceptable Use Policy (AUP) - Vora

Version: 3.2.0 Effective Date: 13 May 2026 Last Updated: 26 May 2026 Authoritative Language: Italian. This English version is a courtesy translation of acceptable-use.it.md. In case of conflict, the Italian version prevails.

This Acceptable Use Policy ("AUP") supplements the Customer Terms of Service (customer-tos.en.md) and the End-User Terms (end-user-tos.en.md) and governs prohibited content and conduct on the Vora platform (the "Platform"), as well as the notice-and-action procedures under Regulation (EU) 2022/2065 ("DSA - Digital Services Act") and substantially equivalent principles of the jurisdictions in which the Platform is accessible (see § 8-bis below).

1. Scope

1.1 This AUP applies to all Platform users: customer organisations (B2B), their collaborators, and End Users (B2C - participants, voters, idea authors).

1.2 Vora S.r.l. (the "Company"), as a hosting service provider under Article 16 of Legislative Decree 70/2003 and Article 6 of Regulation (EU) 2022/2065, does not exercise prior editorial control over uploaded content but applies the procedures described in this AUP upon qualified notices or orders from competent authorities.

2. Prohibited Content (DSA Article 14)

2.1 It is prohibited to upload, publish, transmit or make accessible via the Platform any content that:

a) Is unlawful under Italian or European law, including without limitation:

b) Infringes third-party intellectual or industrial property rights:

c) Infringes third-party personality rights:

d) Constitutes an unfair commercial practice under Articles 18-27-quater of the Italian Consumer Code (Legislative Decree 6 September 2005 no. 206), misleading advertising (Legislative Decree 2 August 2007 no. 145), covert advertising, astroturfing, fake reviews;

e) Violates the discipline of prize contests and prize operations under D.P.R. 26 October 2001 no. 430 (e.g., contest not notified to MIMIT, missing surety, rules not filed);

f) Constitutes vote manipulation on the Platform:

g) Is technically harmful:

h) Violates legal provisions or orders of competent judicial or administrative authorities.

2.2 The above list is non-exhaustive. The Company may update the prohibited content categories in line with regulatory, judicial or technical developments.

3. Prohibited User Conduct

In addition to content, the following conduct is prohibited:

a) use of the Platform in breach of the Terms (B2B or B2C), including attempts to reverse-engineer, decompile, or gain unauthorised access;

b) abuse of reporting features (false reports of lawful content under the Article 5 notice-and-action procedure);

c) mass data extraction from the Platform without authorisation (unauthorised scraping in breach of the Terms and, where applicable, Article 102-bis of Law 633/1941 on database maker's rights);

d) distribution of spam or unsolicited commercial communications via Platform features;

e) impersonation of other users, organisations or the Company (Articles 494 Criminal Code, 73 of Legislative Decree 196/2003 on identity substitution by electronic means).

f) providing social-media accounts or links that the user does not own or is not authorised to use, or that impersonate a third party, including in space Settings or in a participant profile.

4. Consequences of Breach

4.1 In case of breach of this AUP, the Company may, cumulatively:

a) remove or disable access to the illegal content;

b) temporarily suspend the user's account or the organisation's space;

c) permanently close the account or space for serious or repeated breaches;

d) terminate the B2B Agreement under Article 8 of the Customer Terms, by application of the express termination clause under Article 1456 c.c.;

e) notify the competent authorities of the breach, where criminal elements are present (Article 17 D.Lgs. 70/2003 regarding the obligation to communicate to the judicial authority upon request).

4.2 The content removal is communicated to the uploader (author), with reasons and indication of the challenge procedure (Article 6 of this AUP), save where the law requires confidentiality vis-à-vis the notifier.

5. Notice-and-Action Procedure (DSA Article 16)

5.1 The Company makes available to anyone, regardless of registration on the Platform, an illegal content notification procedure under Article 16 of Regulation (EU) 2022/2065.

5.2 Notification may be submitted via:

a) electronic form at voiceofthenewera.com/report.html;

b) email at report@voiceofthenewera.com.

5.3 The notification must contain, under Article 16(2) DSA:

a) a sufficiently substantiated explanation of the reasons why the content is considered illegal;

b) the specific URL of the content or other information allowing identification (e.g., proposal ID, screenshot, hash);

c) name and email of the notifier, save in cases involving offences under Articles 600-ter, 600-quater, 600-quinquies, 609-undecies of the Italian Criminal Code (anonymous reporting permitted);

d) a good-faith statement by the notifier on the correctness and completeness of the information provided.

5.4 The Company acknowledges receipt of the notification without undue delay, normally within 48 working hours.

5.5 The Company takes a reasoned decision on the notification and communicates the outcome to the notifier and the uploader (author), within a reasonable time proportionate to the complexity of the notification, normally within 7 working days, extendable to 14 in particularly complex cases.

5.6 Decisions to remove, suspend, downsize (and decisions to reject the notification) are accompanied by a statement of reasons under Article 17 DSA, indicating:

a) the nature of the content and its location;

b) the facts and circumstances on which the decision was based;

c) any use of automated means in the decision-making process;

d) reference to the legal basis of the decision (law, ToS, AUP);

e) the redress possibilities indicated in Article 6 below.

5.7 The Company keeps an internal register of notifications and decisions taken, also for transparency reporting purposes under Article 15 DSA, where applicable.

6. Internal Complaint Handling System (DSA Article 20)

6.1 The recipient of a moderation decision (content removal, account suspension, demotion) has the right to file a complaint within six (6) months of the decision notification.

6.2 The complaint shall be sent to appeals@voiceofthenewera.com with reference to the contested decision and the grounds of complaint.

6.3 The Company examines complaints in a timely, non-discriminatory, diligent and non-arbitrary manner; the decision on the complaint is taken, normally, within 15 working days of receipt and communicated with reasons.

6.4 The recipient retains the right to apply to a certified out-of-court dispute settlement body under Article 21 DSA, when available for Vora, or to bring action before the competent judicial authority.

7. Trusted Flaggers (DSA Article 22)

7.1 The Company recognises and gives precedence to notifications from trusted flaggers designated under Article 22 DSA (independent bodies certified by the Italian Digital Services Coordinator).

7.2 Trusted-flagger notifications are processed as a priority and the Company takes a decision within 48 working hours of receipt, save in cases of particular complexity.

7.3 The formal trusted-flagger procedure will be activated when AGCOM (the Italian DSA coordination authority) publishes the list of trusted flaggers certified for our subject matter. Until then, the Company accepts qualified notifications from notoriously specialised entities (consumer protection associations, minor protection bodies, etc.) with case-by-case assessment reserved.

8. DSA Single Point of Contact (Article 11)

8.1 The Company designates as single point of contact for competent authorities (European Commission, national authorities - AGCOM in Italy, judicial authorities):

Vora S.r.l. [REGISTERED OFFICE ADDRESS] Email: legal@voiceofthenewera.com Certified email (PEC): [PEC: ____] Working languages: Italian and English.

8.2 The same point of contact is available to service recipients for communications regarding this AUP and DSA procedures.

8-bis. Equivalent Regimes in Non-EU Jurisdictions

8-bis.1 Vora is a Platform technically accessible globally. The DSA procedure set out in the preceding sections is applied by the Company as a higher protection standard, but the following equivalent rules of relevant jurisdictions complement the AUP for users and organisers established therein:

a) United Kingdom - Online Safety Act 2023. The Company applies minors-protection obligations, risk assessment for illegal content and priority illegal content, and an accessible complaint procedure for UK users under the law in force; competent authority: Ofcom.

b) Germany - NetzDG (Netzwerkdurchsetzungsgesetz) - as amended by DSA. For German users, the Company observes removal timelines for "manifestly illegal" content within 24 hours of a qualified notice; competent authority: Bundesnetzagentur.

c) Brazil - Marco Civil da Internet (Lei 12.965/2014) + Lei 14.155/2021. The Company responds to removal requests upon judicial order under Articles 18-19 Marco Civil; competent authorities: ANATEL and/or Brazilian Ministério Público.

d) Australia - Online Safety Act 2021. The Company observes the Basic Online Safety Expectations applicable to platforms accessible to Australian users; competent authority: eSafety Commissioner.

e) United States - Section 230 (47 U.S.C. § 230) + DMCA (17 U.S.C. § 512). The Company operates as an online service provider under Section 230 and implements the DMCA notice-and-takedown procedure for content infringing US copyright; competent authorities: State Attorneys General and US Copyright Office.

f) Catch-all. For other jurisdictions (e.g., India IT Rules 2021, Singapore Online Safety (Miscellaneous Amendments) Act 2022, South Africa POPIA + Films and Publications Act), the Company applies local obligations as additional modules to the DSA procedure, it being understood that the DSA procedure constitutes the minimum protection standard.

8-bis.2 Notices received from users established in non-EU jurisdictions are processed with the same diligence and timing indicated for DSA notices in the preceding sections.

9. AUP Amendments

9.1 The Company may amend this AUP; amendments are published at voiceofthenewera.com/acceptable-use-policy.html and notified to B2B Customers via email with thirty (30) days' notice before entry into force, save for amendments mandated by law with immediate effect.

10. Contacts

Source document in markdown: docs/legal/acceptable-use.en.md (v3.1.0 - 13 May 2026).