COPYRIGHT & TAKEDOWN POLICY

Document Information

Table of Contents

1. Introduction
2. Legal Framework
3. Scope and Definitions
4. Designated Copyright Agent
5. Copyright Infringement Notice Procedure
6. Company Response Procedures
7. Counter-Notification Procedure
8. Statutory Exceptions and Limitations
9. Repeat Infringer Policy
10. Proprietary Tools
11. Protections and Safeguards
12. Liability and Safe Harbour
13. Privacy and Data Protection
14. Abuse and Frivolous Notices
15. Dispute Resolution
16. Digital Services Act Compliance
17. DMCA Provisions for U.S. Users
18. Updates to This Policy
19. Governing Law and Jurisdiction
20. Language
21. Contact
22. Appendix A — Notice Template
23. Appendix B — Counter-Notification Template

1. Introduction

1.1 Visionary Studio s.r.o. ("Company," "we," "us," "our") respects intellectual property rights and is committed to complying with all applicable copyright laws. This Copyright & Takedown Policy ("Policy") establishes the procedures by which copyright owners or their authorised representatives ("Claimants") may report alleged copyright infringement on Visionary Hub ("Platform"), and the procedures by which affected users ("Users") may submit counter-notifications.

1.2 This Policy forms part of the legal framework governing the Service and should be read together with the Terms of Service, Privacy Policy, Acceptable Use Policy, Intellectual Property Notice, Cookie/GDPR Notice, Content Disclaimer, and Branding Guidelines.

2. Legal Framework

2.1 Primary Legal Basis (Czech and EU Law)

This Policy is primarily governed by:

• Czech Copyright Act (Autorský zákon): Zákon č. 121/2000 Sb., protecting original works of authorship including literary, musical, dramatic, pictorial, sculptural, audiovisual works, software, and derivative works.
• Regulation (EU) 2022/2065 (Digital Services Act): Establishing obligations for intermediary service providers, including notice-and-action mechanisms, statement of reasons, and transparency requirements. The DSA liability exemption under Article 6 supersedes the hosting safe harbour previously established under the E-Commerce Directive (2000/31/EC) Article 14.
• Directive (EU) 2019/790 (Digital Single Market Directive): Establishing requirements for reporting and handling copyright infringement by online service providers, including Article 17 obligations.
• Directive 2001/29/EC (InfoSoc Directive): Harmonising copyright and related rights in the information society, establishing the framework for exceptions and limitations.

2.2 Secondary Legal Basis (United States)

For Users located in or accessing the Platform from the United States, this Policy also complies with the Digital Millennium Copyright Act (DMCA), 17 U.S.C. § 512(c), establishing safe harbour provisions for hosting providers. DMCA-specific provisions are set out in Section 17.

2.3 Hierarchy

In the event of any conflict between Czech/EU law and the DMCA, Czech and EU law shall prevail as the governing law of this Policy. DMCA provisions apply to U.S. Users as supplementary protections.

3. Scope and Definitions

3.1 Applicability. This Policy applies to all content hosted on or accessible through the Platform, all Users regardless of geographic location, all third parties reporting copyright infringement, and all content categories including text, images, video, audio, software, and multimedia content.

3.2 Age Requirement. Only persons aged eighteen (18) or older may submit notices or counter-notifications under this Policy, consistent with the Terms of Service §2.2.

3.3 Definitions. Unless otherwise defined herein, capitalised terms have the meanings assigned in the Terms of Service. Additional terms used in this Policy:

• "Claimant" — a copyright owner or authorised representative submitting an infringement notice
• "Infringing Material" — content that allegedly infringes a copyrighted work
• "Counter-Notification" — a formal response by a User contesting the removal of content
• "Repeat Infringer" — a User as defined in Section 9.1
• "Statement of Reasons" — a notice provided under DSA Article 17 explaining the reasons for content removal

4. Designated Copyright Agent

4.1 In accordance with Czech law, applicable EU Directives, and the DMCA, the Company designates the following individual as its authorised representative for receipt of copyright infringement notifications:

4.2 All copyright takedown notices must be submitted to the Designated Copyright Agent using the procedures outlined in Section 5.

5. Copyright Infringement Notice Procedure

5.1 Notice Requirements

To be effective and actionable, a copyright infringement notice must contain all of the following:

5.1.1 Identification of the Copyrighted Work. A clear and specific description of the copyrighted work(s) alleged to have been infringed, including the title, author or copyright holder name, date of original creation or publication, registration details (if applicable), format of the work, and any other distinguishing characteristics.

5.1.2 Identification of Infringing Material. Clear identification of the allegedly infringing material, including complete and precise URL(s) or direct links, description of the location on the Platform, screenshot or other evidence, and specific details explaining how the material infringes the copyrighted work.

5.1.3 Contact Information. Complete contact information for the Claimant: full legal name (or authorised representative name), postal address, telephone number, email address, and company/organisation name with registration number (if a legal entity).

5.1.4 Good Faith Statement. An explicit statement that the Claimant has a good faith belief that the use of the copyrighted material is not authorised by the copyright owner, its authorised agent, or by applicable law.

5.1.5 Declaration of Accuracy. An explicit statement that the information in the notice is accurate and that the Claimant is authorised to act on behalf of the copyright owner. For notices submitted under the DMCA, this statement must be made under penalty of perjury as required by 17 U.S.C. § 512(c)(3)(A)(vi).

5.1.6 Signature. The notice must be signed by the Claimant or an authorised representative. Electronic signatures are acceptable in accordance with Regulation (EU) No 910/2014 (eIDAS) and, for U.S. Users, the DMCA.

5.2 Notice Submission

All copyright infringement notices must be submitted using one of the following methods:

Method 1 — Email: [email protected] (Subject: "COPYRIGHT TAKEDOWN NOTICE — Visionary Hub")

Method 2 — Data Box: sbskxn7

Method 3 — Post: Jakub Liška, Designated Copyright Agent, Visionary Studio s.r.o., V Zahrádkách 742, 273 06 Libušín, Czech Republic

Method 4 — Online Form: The copyright notification form available at the designated legal notices page on our website (when available).

5.3 Incomplete Notices

If a submitted notice does not contain all required information, the Company may request additional information from the Claimant, delay processing until complete information is received, or reject the notice as non-compliant. The Company will notify the Claimant within two (2) business days of determining that a notice is incomplete, specifying which information is required.

6. Company Response Procedures

6.1 Acknowledgment

Upon receipt of a complete copyright infringement notice, the Company will within two (2) business days send written acknowledgment to the Claimant confirming receipt and providing a reference case number.

6.2 Investigation and Evaluation

Within five (5) business days of receiving a complete notice, the Company will investigate the allegation, evaluate whether any statutory exceptions or limitations apply (see Section 8), assess the good faith nature of the complaint, review for potential abuse or false notification, and determine the scope of infringing content.

6.3 Action on Infringing Content

Upon confirming copyright infringement, the Company will remove or disable access to the infringing content, notify the User responsible and provide them with a copy of the takedown notice (redacting sensitive Claimant contact information), provide a Statement of Reasons to the affected User in accordance with DSA Article 17, notify the Claimant that action has been taken, and maintain records of all actions taken.

6.4 Preservation of Evidence

The Company will preserve records of all takedown notices, communications, evidence, timestamps, counter-notifications, and resolution documentation for a minimum of twenty-four (24) months, or longer where required by applicable law, including the ten (10) year retention period under the Czech Accounting Act (zákon č. 563/1991 Sb.) for records with financial implications.

6.5 Expeditious Removal

The Company commits to removing or disabling access to infringing content within five (5) business days of receiving a complete, compliant notice. For content that is manifestly illegal, removal will be expedited.

7. Counter-Notification Procedure

7.1 Right to Counter-Notify

Users who believe that content was wrongfully removed or disabled due to misidentification, mistake, or abuse of the takedown process have the right to submit a counter-notification. This right cannot be restricted or penalised, in accordance with the Acceptable Use Policy §7.4.

7.2 Counter-Notification Requirements

To be effective, a counter-notification must contain:

7.2.1 Identification. Full legal name (or username with associated email), postal address, telephone number, email address, and identification of the specific URL(s) of removed content.

7.2.2 Statement of Belief. An explicit statement that the User has a good faith belief that the content was removed in error or as a result of misidentification.

7.2.3 Explanation. A detailed explanation of why the removal was erroneous, including the legal basis for the use (statutory exception, licence, authorisation, or other).

7.2.4 Consent to Jurisdiction. A statement consenting to the jurisdiction of the courts of the Czech Republic.

7.2.5 Declaration of Accuracy. A statement that the information in the counter-notification is accurate. For counter-notifications submitted under the DMCA, this must be made under penalty of perjury as required by 17 U.S.C. § 512(g)(3)(C).

7.2.6 Signature. Electronic signatures are acceptable.

7.3 Counter-Notification Submission

Counter-notifications must be submitted to [email protected] with subject line "COUNTER-NOTIFICATION — Visionary Hub" or via Data Box sbskxn7.

7.4 Company Response to Counter-Notification

Upon receipt of a compliant counter-notification, the Company will within three (3) business days acknowledge receipt and provide a reference case number; within ten (10) business days evaluate the counter-notification. If valid, the Company will restore the content unless the Claimant has filed a court action seeking injunctive relief, the Claimant provides written evidence of court proceedings, or applicable law prevents restoration. If invalid, the Company will maintain the removal and notify the User with reasoning. The Company will notify the original Claimant of the counter-notification within three (3) business days.

7.5 Restoration

Upon restoring content following a valid counter-notification, the Company will replace the content in its original location with the same permissions and metadata, notify the User, and maintain confidentiality of sensitive information.

8. Statutory Exceptions and Limitations

8.1 Recognition

This Policy recognises that not all uses of copyrighted material constitute infringement. The Company will consider applicable statutory exceptions and limitations before acting on a takedown notice.

8.2 Czech Copyright Act Exceptions (Zákonné licence)

Under §29–40 of the Czech Copyright Act (zákon č. 121/2000 Sb.), lawful uses include quotation for purposes of criticism, review, or scientific work (§31); use for teaching and research purposes (§31a); news reporting and current affairs (§34); incidental inclusion (§38c); and use by libraries, archives, and museums (§37).

8.3 EU Exceptions and Limitations

Under Article 5 of the InfoSoc Directive (2001/29/EC) and the Digital Single Market Directive (2019/790), recognised exceptions include text and data mining for scientific research (Art. 3, DSM Directive), text and data mining with opt-out reservation (Art. 4, DSM Directive), use for illustration in teaching (Art. 5, DSM Directive), and preservation by cultural heritage institutions (Art. 6, DSM Directive).

8.4 Evaluation Process

When evaluating takedown notices, the Company will consider whether the use falls within a recognised statutory exception; the amount and substantiality of material used relative to the copyrighted work; the purpose and character of the use; and the effect on the market for the original work.

8.5 Rejection of Overreaching Notices

The Company may reject notices that target content clearly protected by a statutory exception, grossly misrepresent the scope of infringement, or target content in which the Claimant does not hold rights.

9. Repeat Infringer Policy

9.1 Definition

A "Repeat Infringer" is any User who has received three (3) or more valid copyright infringement notices within any twelve (12) month period, has had content removed three (3) or more times for copyright infringement within any twelve (12) month period, or demonstrates a pattern of deliberate copyright infringement despite previous warnings.

9.2 Enforcement

When a User is identified as a Repeat Infringer, the Company will send written notice explaining the repeat infringer status and consequences; provide a fourteen (14) day opportunity for the User to respond with evidence; conduct a good faith review if the User responds; provide seven (7) day written notice prior to account suspension if repeat infringer status is confirmed; and suspend or terminate the account. The Company provides a Statement of Reasons for all enforcement actions in accordance with the DSA.

9.3 Appeals

Users may appeal their repeat infringer status by providing written evidence that previous notices were submitted in bad faith, contained material factual errors, or that the User's conduct no longer constitutes repeat infringement. Appeals must be submitted within fourteen (14) days of the final notice to [email protected] and will be reviewed by a person not involved in the original determination. The Company will not impose additional penalties solely for exercising the right to appeal.

10. Proprietary Tools

10.1 Distinction. Visionary Hub's Proprietary Tools — micro-applications and utilities developed, owned, and operated by Visionary Studio s.r.o. — are separate from third-party Listed Tools. The intellectual property in Proprietary Tools belongs exclusively to the Company.

10.2 Inapplicability of Takedown. Since Proprietary Tools are owned and operated by the Company, the third-party takedown procedure in this Policy does not apply to disputes about Proprietary Tool functionality or output. Issues regarding Proprietary Tools should be directed to [email protected].

10.3 Data Handling. All data submitted to Proprietary Tools is processed on a session-only basis, is not stored beyond the active session, and is never used for AI model training or shared with third parties, as described in the Terms of Service §3.3.

11. Protections and Safeguards

11.1 Good Faith Removal

The Company will not be liable to any User for removing content based on a compliant notice where the Company acted expeditiously and was not aware of facts indicating the notice was invalid, to the extent permitted by applicable law.

11.2 Claimant Protections

The Company will not disclose the full identity or contact information of Claimants to Users without legal authorisation, except as required by law or court order.

11.3 User Protections

Users whose content is removed will receive a Statement of Reasons, the right to submit a counter-notification, information about available dispute resolution mechanisms, and protection from additional penalties for exercising their right to appeal.

12. Liability and Safe Harbour

12.1 DSA Liability Exemption

The Company operates as an intermediary service provider under Regulation (EU) 2022/2065 (DSA). Under Article 6, the Company benefits from the liability exemption for hosting services provided that the Company has no actual knowledge of illegal content, acts expeditiously to remove or disable access upon obtaining knowledge, and complies with transparency and reporting obligations.

12.2 No Proactive Monitoring

In accordance with DSA Article 8, the Company does not impose a general obligation to monitor User-generated content for copyright infringement. The Company relies on copyright owners and their authorised representatives to report infringement through this Policy's formal procedures.

12.3 DMCA Safe Harbour

For U.S. Users, the Company qualifies for safe harbour protection under 17 U.S.C. § 512(c) as further described in Section 17.

13. Privacy and Data Protection

13.1 In processing notices and counter-notifications, the Company complies with Regulation (EU) 2016/679 (GDPR) and the Czech Personal Data Protection Act (zákon č. 110/2019 Sb.). Personal data is processed solely for the purpose of addressing copyright infringement, with appropriate security measures, limited retention periods, and respect for data subject rights. For full details, see the Privacy Policy.

13.2 The Company will maintain confidentiality of Claimant contact information, not disclose User information to Claimants without legal authorisation, and redact sensitive information when providing notices.

13.3 The Company may request verification that the Claimant is the copyright owner or authorised representative before acting on a notice.

14. Abuse and Frivolous Notices

14.1 Misrepresentation Consequences

Persons who submit notices or counter-notifications that are materially false, made in bad faith, or constitute abuse of this procedure may be subject to liability for damages under applicable law (including 17 U.S.C. § 512(f) for DMCA misrepresentation), barred from submitting future notices, and prohibited from using the Platform.

14.2 Reporting Abuse

Users may report frivolous or abusive notices to [email protected] with subject line "FRIVOLOUS NOTICE REPORT." Reports will be investigated within ten (10) business days.

14.3 Pattern Detection

The Company monitors for patterns of abuse, including simultaneous notices from multiple entities targeting the same User, notices targeting content owned by a competitor, notices from recently created accounts, and notices targeting content with proper licensing.

15. Dispute Resolution

15.1 Internal Escalation

If a User or Claimant believes the Company has misapplied this Policy, they may request escalation review by submitting a written request to [email protected] with the original case reference number, a detailed explanation, and supporting documentation. Escalation requests will be reviewed within ten (10) business days by a person not involved in the original decision.

15.2 Out-of-Court Dispute Resolution

In accordance with DSA Article 21, Users may refer disputes to a certified out-of-court dispute settlement body. The Company will engage in good faith with any such body selected by the User.

15.3 Alternative Dispute Resolution

In accordance with Regulation (EU) No 524/2013, the European Commission provides an online dispute resolution platform at https://ec.europa.eu/consumers/odr. The Company's email for ODR purposes is [email protected].

15.4 Judicial Proceedings

Nothing in this Policy limits the right of any party to seek judicial resolution, including injunctive relief, before the competent courts as specified in Section 19.

16. Digital Services Act Compliance

16.1 This Policy operates within the framework of Regulation (EU) 2022/2065 (Digital Services Act). The Company's broader DSA obligations, including the notice-and-action mechanism for all types of illegal content, trusted flagger cooperation, transparency reporting, and statement of reasons requirements, are detailed in the Acceptable Use Policy §8.

16.2 Statement of Reasons. In accordance with DSA Article 17, the Company provides a clear and specific Statement of Reasons to any User whose content is removed or access disabled, including the facts and circumstances, the legal or contractual basis, and information about redress mechanisms.

16.3 Transparency. The Company publishes annual transparency reports in accordance with DSA Article 15, detailing the number of notices received, notices acted upon, average response time, outcome of counter-notifications, and repeat infringer actions.

17. DMCA Provisions for U.S. Users

17.1 Applicability. This section applies to Users located in or accessing the Platform from the United States, as a supplement to the primary Czech/EU framework.

17.2 DMCA § 512 Compliance. The Company complies with all requirements of 17 U.S.C. § 512(c), including clear identification of the Designated Copyright Agent, reasonable procedures for processing notices, expeditious removal of infringing content, restoration procedures for counter-notifications, and repeat infringer termination policies.

17.3 Penalty of Perjury. Notices and counter-notifications submitted under the DMCA must include the "under penalty of perjury" declarations required by 17 U.S.C. § 512(c)(3)(A)(vi) and § 512(g)(3)(C) respectively. For non-DMCA notices (i.e., submitted under Czech/EU law), a declaration of accuracy is sufficient.

17.4 DMCA Safe Harbour. The Company qualifies for safe harbour protection under DMCA § 512(c) for hosting User-generated content, conditioned on compliance with this Policy.

17.5 Injunctive Relief. Nothing in this Policy limits the right of copyright owners to seek injunctive relief through court proceedings.

18. Updates to This Policy

18.1 Modifications. The Company reserves the right to modify this Policy. Material changes will be posted on the Platform with thirty (30) days' advance notice and communicated via email to registered Users where contact information is available.

18.2 Non-Material Changes. Minor changes (formatting, clarifications that do not alter rights or obligations) take effect immediately upon posting.

18.3 Continued Use. Continued use of the Platform after the notice period constitutes acceptance of the updated Policy. Users who disagree may discontinue use of the Service.

19. Governing Law and Jurisdiction

19.1 Governing Law. This Policy is governed by the laws of the Czech Republic, in particular the Czech Copyright Act (zákon č. 121/2000 Sb.) and the Czech Civil Code (zákon č. 89/2012 Sb.), as well as directly applicable EU law.

19.2 Jurisdiction. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts of the Czech Republic. Venue lies with the Municipal Court in Prague (Městský soud v Praze) or the competent district court, unless mandatory consumer protection provisions require otherwise.

19.3 EU Consumer Rights. Nothing in this Policy affects mandatory consumer rights under applicable EU and national law. EU consumers may bring proceedings in the courts of their Member State of domicile in accordance with Articles 17–19 of Regulation (EU) No 1215/2012 (Brussels I bis).

19.4 Severability. If any provision of this Policy is found to be unenforceable, the remaining provisions shall continue in full force and effect.

20. Language

20.1 Authoritative Version. This Policy is drafted in English, which is the authoritative and legally binding version.

20.2 Czech Translation. A Czech translation is provided for convenience only. In the event of any discrepancy, the English version shall prevail to the extent permitted by applicable law.

21. Contact

Appendix A — Notice Template

[DATE]

TO:  Designated Copyright Agent
     Visionary Studio s.r.o.
     V Zahrádkách 742, 273 06 Libušín, Czech Republic
     Email: [email protected]

RE:  COPYRIGHT TAKEDOWN NOTICE

1. IDENTIFICATION OF COPYRIGHTED WORK:
   Title: ______________________________
   Author/Rights holder: ________________
   Date of creation/publication: _________
   Registration (if any): _______________
   Format: _____________________________

2. IDENTIFICATION OF INFRINGING MATERIAL:
   URL(s): _____________________________
   Location on Platform: ________________
   Description of infringement: __________

3. CONTACT INFORMATION:
   Name: _______________________________
   Address: _____________________________
   Phone: _______________________________
   Email: _______________________________
   Company (if applicable): ______________
   Registration No. (if applicable): _____

4. GOOD FAITH STATEMENT:
   I have a good faith belief that the use of the copyrighted material
   is not authorised by the copyright owner, its agents, or the law.

5. DECLARATION OF ACCURACY:
   I declare that the information in this notification is accurate and
   that I am authorised to act on behalf of the copyright owner.

   [For DMCA notices: I declare under penalty of perjury that the
   information in this notification is accurate and that I am authorised
   to act on behalf of the copyright owner.]

6. SIGNATURE:
   _________________________________
   [Name] | [Date]
   [Electronic signature acceptable]

Appendix B — Counter-Notification Template

[DATE]

TO:  Designated Copyright Agent
     Visionary Studio s.r.o.
     V Zahrádkách 742, 273 06 Libušín, Czech Republic
     Email: [email protected]

RE:  COUNTER-NOTIFICATION

1. IDENTIFICATION:
   Name: _______________________________
   Address: _____________________________
   Phone: _______________________________
   Email: _______________________________
   URL(s) of removed content: ____________

2. STATEMENT OF BELIEF:
   I have a good faith belief that the content was removed in error
   or as a result of misidentification.

3. EXPLANATION:
   [Explain why the removal was erroneous, including legal basis]

4. CONSENT TO JURISDICTION:
   I consent to the jurisdiction of the courts of the Czech Republic.

5. DECLARATION OF ACCURACY:
   I declare that the information in this counter-notification is accurate.

   [For DMCA counter-notifications: I declare under penalty of perjury
   that the information in this counter-notification is accurate.]

6. SIGNATURE:
   _________________________________
   [Name] | [Date]
   [Electronic signature acceptable]

Version History

Document Information: Copyright & Takedown Policy v2.0 — Visionary Hub — Visionary Studio s.r.o.

— END OF COPYRIGHT & TAKEDOWN POLICY —