DSA Information

CLOVERA DSA INFORMATION
Last updated: September 14, 2026
Contact: kitteniversestudios@gmail.com

This document describes how Clovera handles illegal content and moderation decisions, and is written with reference to Regulation (EU) 2022/2065 (the Digital Services Act) for users in the European Union. It describes what the service actually does today, not what it intends to do.

1. Who Operates the Service, and Points of Contact
Clovera is operated under the name "Kitteniverse Studios" by a single natural person, from Türkiye. It is not established in the European Union.

The single electronic point of contact for recipients of the service, for Member State authorities, for the European Commission and for the European Board for Digital Services is kitteniversestudios@gmail.com. It is reached in writing, by electronic means, and communications may be in Turkish or in English. There is no requirement to use an automated tool to reach it.

Article 13 of the Digital Services Act requires a provider that is not established in the Union and that offers its services in the Union to designate a legal representative in one of the Member States concerned. Whether Clovera offers its services in the Union in the sense the Regulation uses depends on whether it has a substantial connection to the Union — an establishment there, a significant number of recipients in one or more Member States relative to their population, or activities directed at one or more Member States.

Clovera has no establishment in the Union, and it does not direct its activities at any Member State. Its landing page, the descriptions it offers to search engines, and the rest of its promotional material are published in English only; they are deliberately not published in German, French, Spanish, Italian or Portuguese, and Clovera does not advertise in any Member State, use a national top-level domain, quote prices in euro, or distribute through a national app store. The interface of the service can be displayed in those languages, at the choice of a user who has already found Clovera and created an account, and its translation feature works between them — that is a function offered to whoever uses the service, not an approach to a market. The operator keeps the remaining criterion, the number of recipients in any one Member State relative to its population, under review, since the answer to it can change as the service grows.

Where a legal representative is designated, this Section gives that person's or entity's name and address, and the designation is notified to the Digital Services Coordinator of the Member State concerned. A recipient of the service, and any authority, may in the meantime address Clovera at the contact point above, and the operator does not treat the absence of a representative as a reason to refuse or delay an answer.

Clovera is a micro enterprise within the meaning of Commission Recommendation 2003/361/EC. Under Article 19 of the Digital Services Act, the obligations for online platforms in Section 3 of Chapter III — among them the internal complaint-handling system of Article 20, out-of-court dispute settlement under Article 21, trusted flaggers under Article 22 and the measures against misuse in Article 23 — do not apply to a provider of that size, and under Article 15(2) the transparency reporting obligation of Article 15(1) does not either. Clovera nevertheless operates the reporting and complaint routes described below, at a scale proportionate to a service run by one person. Where this document describes something Clovera does voluntarily rather than as an obligation, it says so.

2. Reporting Illegal Content
Clovera provides in-service reporting tools that allow a signed-in user to notify Clovera of allegedly illegal content or content that breaks the platform rules. A report carries a category the reporter chooses and a free-text explanation, and identifies the content or the account it is about.

Anyone, whether or not they have an account, may also report content by writing to kitteniversestudios@gmail.com. A report sent that way is easiest to act on when it identifies the content precisely enough to be found — the address of the page or a description of where it appears — explains why the sender considers it illegal or in breach of the rules, gives a name and a contact address, and states that the sender believes in good faith that what it says is accurate and complete. A name and contact address are not asked for where the report concerns an offence referred to in Articles 3 to 7 of Directive 2011/93/EU.

A report submitted through the in-service tool is confirmed on screen at the moment it is submitted. Every report, however it arrives, is recorded and reviewed by a human administrator, and is decided in a timely, diligent, non-arbitrary and objective manner. When the review is concluded, the reporter is told inside the service whether the report was acted on or not, together with the route for asking that the outcome be looked at again. A report sent by email is answered at the address it came from.

Where a report gives Clovera actual knowledge of illegal content, Clovera acts on it expeditiously.

3. Automated Content Review
Clovera uses automated content review, powered by the AI features described in the Privacy Policy, on the categories of content listed there. Automated review may block, remove, or restrict content before any human has seen it. At intervals it also reviews accounts, communities, and groups for spam, deception, and coordinated attacks, using the counts the Privacy Policy describes rather than the content of private or group messages, and it may place a community on hold — hidden from discovery and closed to new members, its existing members unaffected — until a human administrator has looked at it; the hold is reversible. Where its operator has enabled the serious-crime screen described in Section 15(e) of the Privacy Policy, automated review also reads the text of direct and group messages for one purpose — detecting organised and other grave crime within a closed list of categories. That screen is not general monitoring of private conversation: it judges each message against those categories alone, keeps nothing where none is found, removes nothing, and can only place the matter before a human administrator, who decides whether the message is removed and whether any enforcement follows. Clovera does not use automated systems to suspend or terminate accounts, to close communities, to dissolve groups, or to remove private messages; those decisions are taken by a human administrator, who is shown the automated findings and can also set them aside.

Nothing spoken in a call or shown on a shared screen is reviewed, by an automated system or by a person, and none of it is retained: it passes through Clovera's own server and is forwarded without a copy being kept, as Section 8 of the Privacy Policy sets out. A report about conduct in a call is therefore assessed on what the person reporting it can show and on what is known about the accounts concerned, and the account itself can be acted on in the ordinary way.

Clovera is under no general obligation to monitor what is transmitted or stored, or actively to seek facts indicating illegal activity, and does not undertake one. The voluntary measures described in this Section do not deprive Clovera of the liability exemptions in Articles 4 to 6 of the Digital Services Act.

4. Statement of Reasons
Where content a user is submitting is blocked by automated review, the user is told at that moment that the content was not accepted.

Where content already published is removed or restricted, where a community is placed on hold, and where an account is restricted, suspended or terminated, the person affected is entitled to a statement of the reasons, containing: what was done and the territorial scope and duration of it; the facts and circumstances relied on, including whether the matter came from a report or from Clovera's own detection; whether an automated system was used to detect the content and whether one was used in taking the decision; the ground relied on, being either the provision of law the content is said to breach or the provision of the Terms of Service or Community Guidelines it is said to breach, with the reasons why the content is considered to fall within it; and how to contest the decision.

Where an administrator confirms the removal or restriction of something a user posted or sent — a post, a comment, a blog article, a community or channel message, a profile image, or a direct or group message — the person who wrote it is told inside the service that it was removed, on which ground, and how to have the decision reviewed. The full statement of reasons is provided on request to the contact address.

Because Clovera holds no email address for any account, a person whose account has been terminated may have no route back into the service to read a notice left there; in that case the contact address is the route, and a statement of reasons is given on request.

5. Contesting a Decision
A user may contest any moderation decision — a removal, a restriction, a hold on a community, a suspension, a termination, or a decision not to act on a report they made — and ask for it to be reviewed by a person, by writing to kitteniversestudios@gmail.com. A complaint can be made for at least six months after the decision was communicated.

Complaints are handled by a human, not by an automated system, and are decided in a timely, non-discriminatory, diligent and non-arbitrary manner. Where a complaint shows the decision was wrong, it is reversed without delay. Clovera is operated by a single individual, and complaint handling is proportionate to that scale; it is not a staffed appeals process with fixed service levels.

Nothing in this Section limits a user's right to go to court, or to any other remedy available under the law that applies to them.

6. Suspicions of Criminal Offences
Where Clovera becomes aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of one or more persons has taken place, is taking place, or is likely to take place, it promptly informs the law enforcement or judicial authorities concerned and provides what it knows. That decision is taken by a human being on the facts of the case. Where the serious-crime screen described in Section 15(e) of the Privacy Policy is enabled, a finding by it is never in itself such a referral: it opens a case for a human administrator, and any referral follows from that person's assessment.

7. Terms, Restrictions and the Rules Applied
The restrictions Clovera may impose on the use of the service, and the rules it applies in doing so, are set out in the Terms of Service and the Community Guidelines. The role automated tools play in applying those rules, and the human review behind decisions with serious consequences, are described in Section 3 of this document and in Section 15 of the Privacy Policy. Those documents are written in plain language, are available in-app under /legal, and Clovera asks users to accept them again whenever they are materially revised.

8. Transparency
Clovera is exempt from the transparency reporting obligation in Article 15(1) of the Digital Services Act as a micro enterprise. It nevertheless keeps the measurements the Privacy Policy describes — the category and outcome of each report, and daily counters of automated moderation events carrying no identifier, content, or address — and may publish summary information about moderation actions and enforcement categories.

9. Urgent Matters
Clovera may prioritise urgent safety, child protection, terrorism-related, or law-enforcement-related matters where legally appropriate.

10. Orders From Authorities
On receipt of an order to act against illegal content, or an order to provide information, issued by a national judicial or administrative authority under Article 9 or Article 10 of the Digital Services Act, Clovera informs the issuing authority without undue delay of the effect given to the order and when. Where the order concerns a recipient of the service, Clovera informs that recipient of the order and of the redress available against it, at the latest when effect is given to it or at the time the authority specifies.