EU Digital Services Act.
How Circus approaches compliance with the EU Digital Services Act — our obligations as an online platform, content moderation transparency, and how to contact us.
What is the DSA?
The Digital Services Act (DSA) is an EU regulation that came into force on 17 February 2024. It applies to digital services — including online platforms like Circus — that are accessible to users in the European Union, regardless of where the service provider is incorporated.
The DSA establishes a tiered framework of obligations based on service size and type. Circus Corporation is incorporated in Delaware, United States. As a new and growing platform, Circus falls below the “Very Large Online Platform” threshold of 45 million average monthly active EU users and is subject to the obligations applicable to smaller online platforms, rather than the most stringent VLOP obligations.
Our DSA obligations
As an online platform accessible to EU users, Circus is subject to the following obligations under the DSA.
Article 11 — Single point of contact
Circus maintains a designated point of contact for EU member state authorities and the European Commission. All official DSA-related correspondence from EU authorities should be directed to legal@circus.app.
Article 12 — Legal representative in the EU
As a company established outside the EU offering services to EU users, we are assessing our obligations regarding appointment of an EU legal representative under Article 13 DSA. We will publish details of our representative once appointed.
Articles 14–17 — Terms, content moderation & notices
Our Terms of Service set out clearly what is prohibited on Circus. We operate a notice-and-action mechanism — users can report any content via the Report button, and our Trust & Safety team reviews and acts on valid notices promptly.
Article 16 — Notice and action
Any person may submit a notice of allegedly illegal content on Circus. Notices are reviewed by our Trust & Safety team. Where content is found to be illegal, it is removed promptly. We notify the person who submitted the content of the action taken and their right to appeal.
Article 17 — Statement of reasons
When we restrict, remove, or suspend an account or piece of content, we provide the affected user with a clear statement of reasons — the basis for the decision, whether it was made by automated means or a human, and how to challenge it.
Article 20 — Internal complaint-handling
Users who are affected by a content moderation decision have the right to challenge it through our internal appeals process. Appeals are reviewed by a human reviewer who was not involved in the original decision.
Article 24 — Advertising transparency
Our advertising model is in development. When we introduce advertising, we will comply with DSA requirements for advertising transparency — including marking advertisements clearly and making the parameters of targeting available to users.
Article 42 — Transparency reporting
We publish transparency reports covering content moderation actions, takedowns, and account suspensions. Our reports are designed to give EU users and authorities meaningful visibility into how we enforce our rules.
Minors and advertising
The DSA prohibits targeted advertising based on profiling directed at minors. Circus has a global minimum age of 16. We do not target advertising at users we know or reasonably believe to be under 18. Our advertising model does not use sensitive personal data categories for targeting, including health data, political views, or religious beliefs.
Trusted flaggers
The DSA establishes a trusted flagger system — designated organizations whose content notices are given priority processing by platforms. Circus will apply for trusted flagger status recognition where relevant and will implement priority handling for notices from Ofcom-designated and EU-designated trusted flaggers from launch.
Organizations seeking to establish a trusted flagger relationship with Circus should contact legal@circus.app.
Recommender systems
Circus uses recommendation logic to surface content within community feeds and the Discover section. Our recommender systems prioritize content from communities a user has joined and accounts they follow. We do not use off-platform data to drive content recommendations.
Users can control their Discover preferences within their account settings. We will publish a plain-language description of the main parameters of our recommendation logic in line with DSA transparency requirements.
Digital Services Coordinator
The DSA is enforced at member state level by Digital Services Coordinators (DSCs) designated by each EU member state, and at EU level by the European Commission for VLOPs. Circus is not a VLOP and is subject to DSC oversight in the member states where we operate.
For enquiries from Digital Services Coordinators or the European Commission, please contact legal@circus.app. We will acknowledge within 48 hours and designate a point of contact for the matter.
Contact
For all DSA-related enquiries, notices, and regulatory correspondence, use the addresses below.
Legal & Regulatory — legal@circus.app
For DSA notices, authority correspondence, trusted flagger enquiries, and formal legal communications.
Trust & Safety — safety@circus.app
For content notices, appeals, and user safety matters that require urgent Trust & Safety review.