Copyright, Content Licence, and Notice-and-Action Policy

1. Scope and Purpose

1.1. The present Policy governs two connected subjects. The first is the ownership of, and the rights granted over, the material that passes through the DentalPolyglot service, in particular the material imported from a clinic's existing website and republished in translation. The second is the procedure by which any person may report content believed to be illegal, and the manner in which such a report is handled.

1.2. The Service is operated by DTCONCIERGE S.R.L., registered office at Aleea Călărașilor nr. 5, bl. G, ap. 54, Municipiul Sibiu, județul Sibiu, Romania, Trade Register number J2026003869000, unique registration code 53369247, intra-Community VAT identification number RO54852877 (the "Provider", "we", or "us").

1.3. The Policy forms part of the Agreement described in Section 1.3 of the Terms of Service, and terms defined there carry the same meaning here. In matters of content rights and content moderation, the present Policy prevails over the Terms of Service to the extent of any inconsistency.

1.4. Copyright and related rights are governed, as regards the Provider, by Romanian Law no. 8/1996 on copyright and neighbouring rights, republished, read with Directive 2001/29/EC of 22 May 2001, with Directive (EU) 2019/790 of 17 April 2019, and with Directive 96/9/EC of 11 March 1996 on the legal protection of databases. Obligations concerning illegal content are governed by Regulation (EU) 2022/2065 (the "DSA") and, in Romania, by Law no. 50/2024 implementing it.

2. Rights in the Platform

2.1. The Provider owns, or holds the necessary rights in, the Platform Materials, comprising the software and source code of the Service, its templates, layouts, and design systems, its component libraries, its translation pipelines and the instructions driving them, its databases and their structure, its documentation, and the DentalPolyglot name and marks.

2.2. No provision of the Agreement transfers ownership of the Platform Materials, and no right in them arises by implication, by estoppel, or by course of dealing. The rights a Customer acquires are limited to the right to use the Service during the term of the Agreement, in accordance with the Plan to which it subscribes.

2.3. A Customer must not copy, decompile, disassemble, or reverse engineer the Platform Materials, save to the extent such acts cannot lawfully be prohibited, must not remove or obscure a proprietary notice, and must not use the Platform Materials to build a competing service.

2.4. Where a Customer, an Authorised User, or any other person supplies a suggestion, a request, or an idea concerning the Service, the Provider may use it without restriction and without obligation of confidence, attribution, or payment. No personal data and no Tenant Materials are acquired by the Provider through Section 2.4.

3. Rights in the Clinic's Own Materials

3.1. The Customer retains ownership of the Tenant Materials. The Provider claims no proprietary interest in the Customer's text, images, photographs, video, logos, marks, practitioner biographies, pricing information, or clinical descriptions.

3.2. Ownership is unaffected by the fact that the material is hosted by the Provider, is displayed on infrastructure the Provider controls, or has been reformatted, restructured, or translated in the course of building the Tenant Site.

3.3. Where the Customer is not itself the author or the proprietor of an element of the Tenant Materials, but holds a licence permitting the uses described in Section 6, Sections 3.1 and 3.2 operate by reference to that licence rather than to ownership.

4. Authorisation to Import an Existing Website

4.1. The Service is built around the retrieval of the clinic's existing public website. On subscribing to a paid Plan, the Customer authorises the Provider to access that website, to retrieve its pages and the assets they reference, to copy the content, and to store the copy for the purposes described in Section 6.

4.2. The authorisation extends to the specific website the Customer identifies during onboarding, and to any further material the Customer supplies or subsequently designates. The Provider does not retrieve material from a source the Customer has not identified.

4.3. The Customer's original website is not modified, is not replaced, is not redirected, and is not interfered with in any way. Retrieval is read-only, and the Provider acquires no control over the source.

4.4. Retrieval is carried out at a rate that does not burden the source, and the Provider ceases retrieval on request. Where a technical protection measure prevents retrieval, the Provider does not attempt to circumvent it and asks the Customer to supply the material directly.

4.5. Nothing in Section 4 authorises the Provider to retrieve material from a website the Customer does not control. A Customer that identifies a website belonging to another party, whether a former practice, a group to which it no longer belongs, a franchisor, or a competitor, acts in breach of Section 5, and the consequences in Sections 11 and 17 follow.

4.6. A preview of the Service may be requested before any Plan is subscribed, by means of the form published on the Provider's own website. The person making the request identifies a single website and confirms at that moment that the clinic on whose behalf the request is made controls that website and that the Provider may read it. That confirmation authorises the Provider to carry out, in respect of that one website and for the purpose of building the preview alone, the acts described in Section 4.1.

4.7. The authorisation in Section 4.6 is temporary. It subsists only for as long as the preview subsists, it confers no right to publish the preview at a publicly accessible address, and it ends on the earliest of the expiry of the preview link, the revocation of the preview by the Provider, and a request from the person who asked for the preview or from the clinic concerned. Once the preview has expired or has been revoked, the copy retained for it, including the mirrored image assets, is deleted. Where a Plan is subsequently subscribed, Section 4.1 governs from that point and the preview authorisation is spent.

4.8. Sections 4.3, 4.4 and 4.5 apply to a preview as they apply to an import under a Plan.

5. The Customer's Warranty of Rights

5.1. The Customer represents and warrants that it owns, or holds valid, sufficient, and current licences to use and to authorise the Provider's use of, every element of the Tenant Materials, including every element of the website it identifies for import.

5.2. The warranty extends specifically to photographs and illustrations, whether commissioned, purchased, or licensed from a stock library, and to the terms of the licence under which each was obtained, including any restriction on modification, on sub-licensing, on use in translated form, or on use across multiple domains. Many stock licences restrict one or more of those acts, and the Customer confirms that the material it supplies is free of any restriction incompatible with Section 6.

5.3. The warranty extends to typefaces and font files, whose licences frequently distinguish between desktop use and web use, and whose web licences are frequently limited by domain or by monthly page views. The Customer confirms that any typeface it asks the Provider to reproduce is licensed for web use on the domains on which the Tenant Site is published.

5.4. The warranty extends to video, to audio, to music, and to any embedded third-party component, and to the trade marks, logos, and certification marks appearing in the material, including marks belonging to professional bodies, to accreditation schemes, to equipment manufacturers, and to treatment-system proprietors. Use of such a mark frequently requires the proprietor's authorisation, and the Customer confirms that it holds any authorisation required.

5.5. The warranty extends to portraits and images of identifiable individuals, including practitioners, staff, and patients, and to the rights of those individuals in their own image.

5.6. The Customer must notify the Provider without delay where it becomes aware that an element of the Tenant Materials is, or may be, infringing, or where a licence supporting it expires, is withdrawn, or is found not to cover the uses described in Section 6. On notification, the Provider removes or replaces the element concerned in cooperation with the Customer.

5.7. The person requesting a preview under Section 4.6 gives the warranty in Section 5.1 in respect of the website identified in the request, and Sections 5.2 to 5.6 apply to that website as they apply to the Tenant Materials.

6. The Licence Granted to the Provider

6.1. The Customer grants the Provider a non-exclusive, worldwide, royalty-free, sub-licensable licence to reproduce, store, host, adapt, restructure, reformat, translate into the languages the Customer selects, publicly display, publicly communicate, and transmit the Tenant Materials.

6.2. The licence is granted solely for the purposes of building, operating, supporting, securing, backing up, and improving the Service supplied to that Customer. No other use is permitted, and the Provider does not use the Tenant Materials to promote itself without the Customer's separate written consent, save that the Provider may identify the Customer as a customer by name and logo unless the Customer objects in writing.

6.3. The right to translate and to adapt is granted expressly because a translation constitutes a derivative work under Romanian Law no. 8/1996, and because the right to authorise a translation belongs to the author. A general licence to host would not carry the right to translate, and the express grant in Section 6.1 supplies it.

6.4. The power to sub-license extends only to the sub-processors and technical providers engaged in supplying the Service, and only to the extent necessary for each of them to perform its function. No sub-licence confers a right to use the Tenant Materials for the sub-processor's own purposes.

6.5. The licence subsists for the term of the Agreement and, thereafter, for the retention periods described in Section 22 of the Terms of Service, so that the export window may operate and so that backups may expire in the ordinary course. On expiry of those periods the licence ends.

6.6. The licence is granted for the operation of the Service and not as a transfer of any moral right. Moral rights, including the right of attribution and the right to object to derogatory treatment, remain with their holders as Romanian law provides.

7. Translated Versions, and What Happens on Exit

7.1. The multilingual rendering of the Tenant Materials produced by the Service is a derivative work created from the Customer's material. The underlying rights remain the Customer's, and nothing in the production of a translation diminishes them.

7.2. So far as any separate right subsists in the translated rendering as such, and in the structure, arrangement, and presentation the Provider applies to it, the Provider grants the Customer, on termination of the Agreement for any reason other than termination for the Customer's unlawful use, a perpetual, irrevocable, worldwide, royalty-free, non-exclusive licence to use, reproduce, modify, publish, and further translate the exported translated text for its own business purposes, including on a website operated by another supplier.

7.3. The licence in Section 7.2 covers the translated text and the content of the Tenant Site. The licence does not extend to the Platform Materials, to the templates, layouts, design systems, and component libraries in which the content is presented, or to the software producing the translation, none of which is exported and none of which may be reproduced.

7.4. Section 7.2 exists so that the Customer's investment in translated content is not lost on exit, and so that no rights obstacle arises to the switching regime described in Section 17 of the Terms of Service. No charge is made for the licence, and no charge is made for the export.

7.5. Where the Provider has removed content from the Tenant Site because it was found to be illegal or infringing, the licence in Section 7.2 does not extend to that content, and the Provider is not obliged to export it.

8. Patient Images, Testimonials, and Before-and-After Material

8.1. Photographs of patients, clinical images, radiographs, testimonials attributed to identified patients, and material presenting a treatment outcome by comparison of images taken before and after treatment engage both copyright and data protection, and frequently engage professional advertising rules as well.

8.2. An image from which a patient can be identified is personal data. Where the image records a clinical condition or a treatment, it is also data concerning health and constitutes a special category under Article 9 of Regulation (EU) 2016/679. Publishing such an image requires an appropriate basis under Article 9, which in the ordinary case of marketing material is the explicit consent of the patient.

8.3. The Customer warrants that it holds, for every patient image, testimonial, or comparative presentation supplied for publication, the patient's explicit, informed, specific, and documented consent to publication in that form, on a website, in each language in which the Tenant Site is published, and for the period during which publication continues. Consent to clinical use of an image is not consent to its publication, and the Customer confirms that it does not treat one as the other.

8.4. The Customer must operate a mechanism by which a patient may withdraw consent, and must instruct the Provider to remove the material without delay when consent is withdrawn. On such an instruction, the Provider removes the material from every language version of the Tenant Site.

8.5. Several markets restrict or prohibit the use of comparative before-and-after presentations and of patient testimonials in the advertising of dental services, and the restrictions differ from country to country. Because the Tenant Site is published in several languages and addressed to patients in several countries, the Customer must satisfy itself that the material complies with the rules of every market the Tenant Site targets, and not only with those of the country in which the practice is established.

8.6. The Provider does not assess whether a consent has been validly obtained and does not verify compliance with the advertising rules of any market. Where the Provider becomes aware that material of the kind described in Section 8.1 appears to be published without an adequate basis, the Provider may remove or restrict it pending clarification, and Section 14 applies.

9. Advertising and Clinical Claims in Imported Content

9.1. Material imported from an existing website frequently contains claims that were composed for one audience and become problematic when translated for another, including superlatives, guarantees of outcome, statements of comparative superiority, references to prices without the qualifications a market requires, and descriptions of procedures reserved to particular professional titles.

9.2. The Customer remains responsible for such claims after translation, exactly as before it, and Section 11 of the Terms of Service governs the standards that apply. A claim that has appeared on the Customer's own website for years acquires no immunity by being reproduced through the Service.

9.3. Where the Customer practises in Romania, the applicable framework includes the Code of Ethics of the College of Dental Physicians of Romania of 9 July 2021 and Decision no. 1/1AGN of 21 March 2025 of that College, applicable from 1 July 2025, under which dental advertising must be realistic, objective, relevant, verifiable, discreet, truthful, and clear, and must not be false, misleading, or deceptive.

9.4. The Provider operates an automated check flagging language commonly prohibited in the markets served, together with a review queue applied before publication. Both are voluntary own-initiative investigations within the meaning of Article 7 of the DSA. Neither is an undertaking to detect every non-compliant claim, and neither transfers responsibility for the content to the Provider.

9.5. Where a claim is flagged, the Provider raises it with the Customer, and publication of the item concerned is held until the Customer amends it or confirms in writing that it is compliant in every market the Tenant Site targets. A confirmation given under Section 9.5 forms part of the warranty in Section 5 and is covered by the indemnity in Section 11.

10. Reporting an Infringement of the Provider's Own Rights

10.1. Where a person believes that the Provider's Platform Materials, name, or marks are being used without authorisation, the matter should be reported to service@dentalpolyglot.com with particulars sufficient to identify the use complained of.

10.2. Section 10 concerns the Provider's own rights. Reports concerning content published on a Tenant Site, whatever their subject, are handled under Sections 12 to 20.

11. Indemnity

11.1. The Customer, and a person giving the warranty under Section 5.7, indemnifies the Provider, and holds it harmless, against all claims, demands, proceedings, liabilities, damages, fines, penalties, settlements, and reasonable costs, including reasonable legal fees, arising out of or in connection with a breach of the warranties in Sections 5, 8, and 9, or a breach of Section 11 of the Terms of Service.

11.2. The indemnity extends to a claim brought by the proprietor of a right in imported material, by a stock library, by a typeface foundry, by a photographer, by a professional body, by an individual whose image or personal data has been published without an adequate basis, and by a competent authority acting in respect of advertising or professional-conduct rules.

11.3. The Provider will notify the Customer of a claim without undue delay, will not admit liability or settle without the Customer's consent, which is not unreasonably withheld or delayed, and will give the Customer reasonable assistance at the Customer's expense. The Provider retains the right to conduct its own defence where the claim also concerns the Platform Materials or where the Customer does not assume the defence promptly.

11.4. The indemnity is not subject to the financial limits in Section 20.2 and Section 20.3 of the Terms of Service, save as Romanian law otherwise requires.

11.5. Nothing in Section 11 obliges the Customer to indemnify the Provider in respect of loss caused by the Provider's own breach, negligence, or unlawful act.

12. Reporting Illegal Content: the Notice Mechanism

12.1. Any individual or entity may notify the Provider of information present on a Tenant Site, in a message thread, in the Conversation Layer, or elsewhere within the Service that the notifier considers to be illegal content. The mechanism is established under Article 16 of the DSA, is available without registration, and is free of charge.

12.2. A notice is submitted by electronic mail to service@dentalpolyglot.com, which is the channel the Provider operates for the purpose and which satisfies the requirement in Article 16(1) of the DSA that the mechanism be easy to access, user-friendly, and capable of receiving notices exclusively by electronic means. Where a reporting form is made available on the Provider's website, a notice may be submitted through that form instead, and neither channel takes precedence over the other. Notices are accepted in English and in Romanian.

12.3. To be effective, a notice must contain a sufficiently substantiated explanation of the reasons why the notifier alleges the information to be illegal content; a clear indication of the exact electronic location of the information, in the form of the exact address or addresses concerned or, where the information is a message, the thread or message identifier, together with any further information necessary to identify it; the name and electronic mail address of the notifier, save where the notice concerns an offence referred to in Articles 3 to 7 of Directive 2011/93/EU, for which the particulars of the notifier are not required; and a statement confirming the notifier's bona fide belief that the information and allegations contained in the notice are accurate and complete. The elements are set out above in the order in which a notice may conveniently be composed, which is how the Provider discharges the obligation in Article 16(2) of the DSA to enable and to facilitate the submission of sufficiently precise and adequately substantiated notices. A notice omitting one of them is not rejected on that ground alone, and the Provider instead identifies what is missing and invites the notifier to supply it.

12.4. A notice satisfying Section 12.3 is presumed to give rise to actual knowledge or awareness for the purposes of Article 6 of the DSA in respect of the specific item concerned, where it allows a diligent provider to identify the illegality without a detailed legal examination.

12.5. Submitting a notice in bad faith, or containing statements known to be false, may give rise to liability under the applicable law, and the Provider may decline to process further notices from a notifier who repeatedly submits manifestly unfounded notices.

13. How a Notice Is Handled

13.1. Where the notice contains the notifier's electronic contact details, the Provider confirms receipt without undue delay.

13.2. The notice is recorded, together with the date of receipt, the notifier's contact details, the exact location of the information, the illegality alleged, the assessment made, the decision reached, and the dates of each step. The record is retained so that the handling of the matter can be reconstructed.

13.3. The Provider assesses the notice in a timely, diligent, non-arbitrary, and objective manner. Assessment considers the content complained of, the law said to be infringed, the market in which the content is published, the language in which it appears, and any representation made by the Customer that published it.

13.4. The Provider may decide to remove the information, to disable access to it, to restrict its visibility, to replace it, to ask the Customer to amend it within a stated period, to suspend or restrict the account or the provision of the Service, or to reject the notice. Where the assessment is finely balanced and the content falls within a category the Provider has identified as high risk, in particular unlawful medical or dental advertising, the Provider will ordinarily restrict the item and invite the Customer to amend it rather than leave it published while the question is resolved.

13.5. The Provider informs the notifier of the decision without undue delay, together with information on the possibilities for redress in respect of it.

13.6. Where automated means were used in processing or in deciding upon the notice, the Provider discloses that fact to the notifier, in accordance with Article 16(6) of the DSA.

13.7. Assessment is carried out by a member of staff. Automated tools are used to locate content and to flag categories of language, and are not used as the sole basis for a decision to restrict.

14. Statement of Reasons to the Affected Customer

14.1. Where the Provider removes information, disables access to it, restricts its visibility, or replaces it, or suspends or restricts an account or the provision of the Service, on the ground that the information is illegal content or is incompatible with the Terms of Service, the Provider sends the affected Customer a statement of reasons at the latest when the measure takes effect.

14.2. The statement is clear, easily comprehensible, precise, and specific, and contains all of the following. It states whether the measure entails removal, the disabling of access, a restriction of visibility, or the suspension or restriction of the account or the Service, together with its territorial scope and its duration. It sets out the facts and circumstances relied upon in reaching the decision, including whether the decision was taken in response to a notice or on the Provider's own initiative, and, where strictly necessary, the identity of the notifier. It discloses whether automated means were used in detecting or identifying the information or in taking the decision, and identifies the tool concerned where the automated advertising check contributed. Where the decision concerns allegedly illegal content, it gives the legal ground relied upon and explains why the information is considered illegal on that ground. Where the decision rests on incompatibility with the Terms of Service, it gives the contractual provision relied upon and explains why the information is considered incompatible with it. It sets out, in clear and accessible terms, the possibilities available to the Customer for contesting the decision.

14.3. A statement of reasons is not sent where the Provider does not hold electronic contact details for the recipient concerned, where the information constitutes deceptive high-volume commercial content, or where the measure is taken pursuant to an order under Article 9 of the DSA, in which case Section 16 applies instead.

14.4. A pause of the Tenant Site for non-payment under Section 10 of the Terms of Service is a suspension of performance rather than a restriction imposed on grounds of illegality or incompatibility of content, and accordingly does not attract a statement of reasons.

15. Contesting a Decision

15.1. A Customer that wishes to contest a measure may reply to the statement of reasons or write to service@dentalpolyglot.com, setting out why the measure should be reversed and supplying any material supporting the position.

15.2. The matter is re-examined by a member of staff who did not take the original decision. Where the re-examination concludes that the measure was wrong, the content is restored or the restriction lifted without delay, and the Customer is informed.

15.3. A notifier dissatisfied with a decision may write to the same address, setting out why the assessment should be revisited, and the matter is re-examined on the same basis.

15.4. The Provider is a provider of hosting services and is not an online platform for the purposes of Section 3 of Chapter III of the DSA. The internal complaint-handling system under Article 20 of the DSA and the out-of-court dispute settlement procedure under Article 21 of the DSA apply to online platforms, are not available in respect of the Service, and are not offered. The re-examination described in Sections 15.1 to 15.3 is provided voluntarily.

15.5. The right of any party to seek a remedy before a competent court is unaffected, and nothing in Section 15 conditions access to a court on the exhaustion of the procedure described here. Any person may also address the Digital Services Coordinator designated in Romania under Law no. 50/2024.

16. Orders From Competent Authorities

16.1. On receipt of an order to act against one or more specific items of illegal content, issued by a competent national judicial or administrative authority under Article 9 of the DSA, the Provider gives effect to the order and informs the issuing authority of the effect given and of the date on which it was given.

16.2. On receipt of an order to provide specific information about one or more specific recipients of the service, issued under Article 10 of the DSA, the Provider responds in the same manner.

16.3. At the latest when effect is given to an order, the Provider informs the affected Customer of the order, of the reasons stated in it, and of the redress available, unless the order or the applicable law prohibits the Provider from doing so or postpones the notification.

16.4. The Provider examines each order for compliance with the requirements the DSA imposes, including the statement of the legal basis, the identification of the exact address of the content concerned, the information on redress, and the language in which the order is drawn. Where an order is defective, the Provider says so to the issuing authority and asks for it to be rectified.

16.5. Every order and every response is recorded in the same manner as a notice under Section 13.2.

17. Repeated Infringement

17.1. Where a Customer repeatedly publishes content found to be illegal or infringing, the Provider may restrict the account, may impose a requirement of prior review on further publication, and may suspend or terminate the Agreement under Section 21 of the Terms of Service.

17.2. In deciding what measure to take, the Provider considers the number and the gravity of the instances, whether the Customer corrected them promptly, whether the Customer supplied assurances that proved inaccurate, and whether the instances arose from a single underlying cause capable of being remedied.

17.3. A measure under Section 17.1 attracts a statement of reasons under Section 14, and may be contested under Section 15.

18. The Provider's Position Under the Liability Rules of the Digital Services Act

18.1. The Provider stores information supplied by, and at the request of, recipients of the service, and is accordingly a provider of hosting services within the meaning of Article 3(g)(iii) of the DSA.

18.2. The exemption from liability in Article 6 of the DSA is available to a provider whose role in relation to the stored information is merely technical, automatic, and passive. The Provider states its position candidly rather than asserting the exemption without qualification.

18.3. For the content of a Tenant Site, the Provider builds, restructures, translates, and reviews the material before publication. Such involvement gives the Provider knowledge of, and control over, that content, and the Provider therefore does not assume that the exemption in Article 6 of the DSA extends to it. Protection in respect of that content is contractual, and rests on the Customer's warranty in Section 5, on the review-and-acceptance process in Section 6.3 of the Terms of Service, which attributes the published result to the Customer's own editorial decision, and on the indemnity in Section 11.

18.4. For content stored without the Provider's editorial involvement, in particular patient uploads and the messages exchanged in a thread or through the Conversation Layer, which are processed automatically, the exemption in Article 6 of the DSA can apply. The Provider is not liable for such content absent actual knowledge or awareness, and acts expeditiously once it obtains either.

18.5. The duties in Articles 16, 17, and 18 of the DSA apply irrespective of whether the exemption is available in a given case, and the Provider observes them across the whole of the Service.

18.6. No general obligation to monitor stored information, or actively to seek facts indicating illegal activity, is imposed on the Provider, in accordance with Article 8 of the DSA. The voluntary measures described in Section 9.4 do not, under Article 7 of the DSA, cause the Provider to forfeit an exemption that would otherwise be available, and equally do not create a neutral position in respect of content the Provider has helped to compose.

18.7. As a microenterprise, the Provider is exempt from the transparency reporting obligations in Article 15 of the DSA and from the obligations applicable to online platforms in Section 3 of Chapter III. Exemption from reporting does not affect the substantive duties described in the present Policy.

19. Suspicions of Criminal Offences

19.1. Where the Provider becomes aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of a person or persons has taken place, is taking place, or is likely to take place, the Provider promptly informs the law-enforcement or judicial authorities of the Member State or Member States concerned, and supplies the relevant information available to it, in accordance with Article 18 of the DSA.

19.2. Where the Member State concerned cannot be identified, the Provider informs the law-enforcement authorities of Romania, or Europol, and takes such further step as the circumstances require.

19.3. Awareness may arise from a notice, from the review queue, from a support enquiry, or from a message passing through the Service. No proactive monitoring is undertaken in order to generate such awareness, and none is required.

19.4. Personal data disclosed under Section 19 is disclosed on the basis of Article 6(1)(c) of Regulation (EU) 2016/679, and the disclosure is recorded.

20. Restoration of Content

20.1. Where content has been removed or restricted and the Provider subsequently concludes, whether on re-examination under Section 15 or otherwise, that the measure was not justified, the content is restored without delay and without charge, and the Customer is informed.

20.2. Where content was removed pursuant to an order that is subsequently annulled, withdrawn, or set aside, the content is restored unless a separate ground for its removal subsists.

20.3. Restoration is not possible where the retention periods in Section 22 of the Terms of Service have expired and the content has been deleted in the ordinary course. Where a decision is contested within the periods provided, the Provider preserves the content concerned until the matter is resolved.

21. Why the Digital Millennium Copyright Act Does Not Govern the Service

21.1. The Provider is established in Romania, contracts under Romanian law, addresses its Service to clinics in Europe, and hosts content directed principally at patients in the European Economic Area, the United Kingdom, and Norway. The notice-and-takedown regime in Title II of the United States Digital Millennium Copyright Act, codified at 17 U.S.C. section 512, is a limitation on liability under United States federal law and does not establish the framework governing the Service.

21.2. The corresponding framework is the one described in Sections 12 to 20, established by the DSA and, in Romania, by Law no. 50/2024. A rightsholder wishing to complain of an infringement in content published through the Service should use the mechanism in Section 12, which is the effective route and the one to which the Provider is obliged to respond.

21.3. The Provider has not designated an agent under 17 U.S.C. section 512(c)(2), and does not hold itself out as operating a procedure under that provision. A communication framed as a notice under that Act is nevertheless treated as a notice under Section 12, provided it contains the elements listed in Section 12.3, and the Provider will say so to the sender rather than declining it on a point of form.

21.4. One qualification is recorded for completeness. The Conversation Layer plugin is distributed through the WordPress plugin directory, which is operated from the United States and applies its own procedures, including procedures under United States copyright law, to material hosted in that directory. A complaint concerning the plugin listing itself, as distinct from content published through the Service, may accordingly fall to be addressed to the directory operator, and the Provider will assist in identifying the correct route.

22. Contact Points

22.1. The single point of contact for the authorities of the Member States, the European Commission, and the European Board for Digital Services, designated under Article 11 of the DSA, is service@dentalpolyglot.com. Communications are accepted in English and in Romanian, which satisfies the requirement in Article 11(3) that a provider declare a language including an official language of the Member State in which it is established.

22.2. The point of contact for recipients of the service, designated under Article 12 of the DSA, is the same address. A member of staff answers, and no recipient is required to use an automated tool in order to communicate with the Provider.

22.3. Copyright matters, licensing questions, and notices concerning content are all directed to service@dentalpolyglot.com. Matters concerning personal data are directed to privacy@dentalpolyglot.com and are addressed in the Privacy Policy.

22.4. DTCONCIERGE S.R.L., Aleea Călărașilor nr. 5, bl. G, ap. 54, Municipiul Sibiu, județul Sibiu, Romania. Website: https://dentalpolyglot.com.