Exclusion and Sanctions Policy

Effective date: 22 August 2026, version 0.1 (draft). This policy forms part of the Trademeup Terms of Service (operator: TTA Technologies, {{COMPANY_ADDRESS}}, RCS {{RCS_NUMBER}}, VAT {{VAT_NUMBER}}). It also implements the requirements of Regulation (EU) 2022/2065 (Digital Services Act, "DSA").

1. Grounds for Sanctions

Measures under this policy may be taken in particular in the event of:

a) offering prohibited items, in particular counterfeits (prohibited-items.md); b) illegal content (e.g. copyright or trademark infringements, defamatory content); c) deception about identity, seller status (private/pro) or item condition; d) non-performance of orders, an excessive miss or cancellation rate, repeatedly late dispatch; e) abuse of Buyer Protection, the dispute system or the review system; f) circumvention of the Platform or of fees, soliciting payments outside checkout; g) multiple accounts to evade measures; h) payment irregularities, chargeback abuse, fraud or attempted fraud; i) frequent submission of manifestly unfounded notices or complaints (Art. 23 DSA); j) other material breaches of the Terms or of statutory law.

2. Graduated Measures

We select the measure according to the nature, severity, frequency and consequences of the violation and the degree of fault. The levels are:

1. Notice: information about the violation with a request to remedy it (e.g. correction of a listing).
2. Warning: formal warning; further violations will result in restrictions.
3. Restriction: temporary or function-related limitation, e.g. removal of individual listings, withdrawal of selling privileges, visibility restrictions, suspension of the Pro badge, suspension of participation in Buyer Protection, limits on new listings.
4. Suspension: temporary or permanent suspension of the account; in the case of permanent suspension, extraordinary termination of the user agreement.

In the case of serious violations (in particular intentional counterfeiting, fraud, stolen goods), levels may be skipped and immediate removal and suspension imposed.

3. Counterfeits: Zero Tolerance

3.1 Listings that, following our review, concern counterfeits are removed immediately.

3.2 Intentionally offering counterfeits results in permanent suspension of the account.

3.3 Pending payouts may be withheld until the matter is clarified (suspension of the payout via the payment service provider), to the extent and for as long as this is necessary to secure refund claims of affected buyers or to investigate the matter.

3.4 We reserve the right to inform rights holders and law enforcement authorities and to preserve evidence.

4. Statement of Reasons for Every Measure

4.1 For every measure against content or accounts (removal, visibility restriction, suspension or termination of the service, suspension of payments, account suspension), the affected user receives a clear and specific statement of reasons in accordance with Art. 17 DSA. The statement of reasons includes in particular:

• the type of measure and, where applicable, its duration and territorial scope;
• the facts and circumstances relied on, including whether the measure is based on a notice or on our own review;
• the legal basis or the contractual basis (clause of the Terms) and an explanation of why the facts fall under it;
• where applicable, information on the use of automated means;
• the available remedies (internal complaint-handling system, out-of-court dispute settlement, courts).

4.2 No statement of reasons is provided where this is excluded by law (e.g. an official order subject to confidentiality) or where the content concerned is deceptive high-volume commercial content.

5. Reporting System for Content and Users

5.1 Any person may report content to us via the Platform's reporting system (the "Report" button on listings, reviews and profiles) or by e-mail to [email protected] where they consider it illegal or in breach of our terms (Art. 16 DSA).

5.2 Reports should contain: a statement of reasons, the exact location (URL/listing ID), the reporting person's name and e-mail address (except for certain offences, which may be reported anonymously) and a statement that the report is made in good faith.

5.3 We confirm receipt, review reports diligently, in a timely and non-arbitrary manner, and notify the reporting person of our decision, including available remedies. Reports from trusted flaggers are treated with priority.

6. Internal Complaint-Handling System

6.1 Affected users may lodge an internal complaint against decisions (measures as well as the rejection of a report) free of charge within a period of at least six months from notification of the decision (Art. 20 DSA), via the user account or by e-mail to [email protected].

6.2 Complaints are handled in a timely, diligent and non-discriminatory manner under the supervision of qualified staff; decisions are not taken solely on the basis of automated means. If a complaint is upheld, we reverse the measure without undue delay.

6.3 Independently of this, users may turn to a certified out-of-court dispute settlement body (Art. 21 DSA) and to the courts. The Digital Services Coordinator competent for Luxembourg is the Autorité de la concurrence (review point: verify the competent authority and certified dispute settlement bodies before publication).

7. Contact Point

Single point of contact for authorities and users (Art. 11, 12 DSA):

• E-mail: [email protected]
• Languages: German, English, French
• Postal address: TTA Technologies, {{COMPANY_ADDRESS}}

8. Consequences of Suspension

8.1 Upon suspension, the user's listings are ended; ongoing orders are duly completed or refunded. Access to legally required documents (e.g. invoices) remains possible.

8.2 Balance from gift cards, credits and refunds is not affected by a suspension unless it derives from the sanctioned conduct; reimbursement follows the statutory rules.

8.3 Withheld payouts are released after clarification or used to refund affected buyers. Further claims (damages) remain reserved.

8.4 Creating new accounts to circumvent a suspension is prohibited; such accounts may be suspended without further notice.

9. Repeated Violations and Manifestly Unfounded Reports

Users who frequently provide manifestly illegal content are, after prior warning, suspended for a reasonable period (Art. 23 DSA). The same applies, with regard to the use of the reporting and complaint systems, to persons who frequently submit manifestly unfounded reports or complaints.

---

Contact: [email protected]