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Notice of Designated Agent and Published Takedown Process

Effective Date: 2026-04-29

Surface posture (precondition). AskTilly's user-storage surfaces are limited to (i) one-to-one AI assistant sessions and (ii) invite-only, closed-membership multi-user chat rooms with an end-to-end-encryption default. AskTilly does not operate any public-dissemination surface — no public discovery, no public search, and no public-room concept. AskTilly is therefore a provider of a hosting service within the meaning of Article 3(g)(iii) of Regulation (EU) 2022/2065 (the "DSA") and is not an "online platform" within the meaning of Article 3(i) DSA. The takedown regime described below, the SLA in § 4, and the representative arrangements in § 11 are calibrated to that surface posture.

Statute anchors. EU Digital Services Act, hosting-tier obligations at Articles 11–18 — in particular Articles 11 (point of contact for authorities), 12 (point of contact for users), 13 (legal representative), 16 (notice and action), 17 (statements of reasons), and 18 (notification of suspicions of criminal offences). The online-platform-tier obligations of Articles 19–28 DSA (including the Article 20 internal complaint-handling system, the Article 21 out-of-court dispute-settlement obligation, the Article 22 trusted-flagger regime, the Article 24 online-platform transparency-reporting regime, and the Article 28 minor-protection obligations) are not within scope because AskTilly is not an online platform under Article 3(i) DSA. UK Online Safety Act 2023, Part 3 — illegal-content safety duties (sections 9–12), content-reporting duty (section 20) and complaints-procedure duty (section 21), as supplemented by Ofcom's Illegal-Harms Codes of Practice. Brazil Marco Civil da Internet (Lei 12.965/2014) Article 19 (as modulated by STF Tema 987, judgment of 2025-06-26 — notice-and-takedown is now the default; the prior judicial-order rule survives only for crimes against honour), and Código de Defesa do Consumidor (Lei 8.078/1990) Article 37 (misleading commercial practices on sponsored surfaces, where applicable). United Arab Emirates Federal Decree-Law No. 34/2021 on Combating Rumours and Cybercrime, where AskTilly is reachable from the UAE (cooperation with competent-authority orders only — AskTilly does not currently target UAE consumers). Australia: Online Safety (Basic Online Safety Expectations) Amendment Determination 2024 (registered 30 May 2024, effective 31 May 2024), which extended the 2022 BOSE Determination to address generative AI, recommender systems, child best-interests, and resourcing decisions, together with current eSafety regulatory guidance. 18 U.S.C. § 2258A (CyberTipline reporting), as amended by the REPORT Act of 2024 (Pub. L. 118-59, 2024-05-07): § 2258A(a) requires reporting "as soon as reasonably possible" after obtaining actual knowledge of apparent CSAM, and § 2258A(h) requires preservation for one year following submission to the CyberTipline. Take It Down Act, Public Law 119-12 (signed 2025-05-19) — Section 3 of the Act (platform notice-and-removal duty), codified at 47 U.S.C. § 223a, applies on its terms to "covered platforms": websites, online services, online applications, or mobile applications that serve the public and either (A) primarily provide a forum for user-generated content, or (B) in the regular course of trade or business publish, curate, host, or make available non-consensual intimate visual depictions. Given AskTilly's surface posture above (no public-dissemination surface; user-storage limited to one-to-one AI sessions and invite-only end-to-end-encrypted rooms), AskTilly does not squarely satisfy either prong and is on the residual edge of "covered platform" within the meaning of TIDA. Where a TIDA-eligible notice does reach AskTilly, AskTilly accepts and processes it on the hosting-tier track described in § 4 below. Section 2 of the Act (criminal offense), enacted by amendment to 47 U.S.C. § 223, and the pre-existing federal civil cause of action at 15 U.S.C. § 6851 (Pub. L. 117-103, 2022 VAWA reauthorization), are not platform-duty sections and are referenced for completeness only.

1. Designated Agent

AskTilly designates the following individual as its agent for receipt of takedown notices and related communications under the statutes listed above:

The designated agent is reachable at the postal address and email above. Notices delivered by other means (postal mail to other AskTilly addresses, social media, support tickets) may be redirected by AskTilly staff to the designated agent but are not deemed received until the designated agent receives them.

2. Scope

This process applies primarily to notices arising under the EU Digital Services Act, hosting-tier obligations at Articles 11–18, and in particular Article 16 (notice and action) and Article 17 (statements of reasons). AskTilly is a provider of a hosting service within the meaning of Article 3(g)(iii) DSA. AskTilly is not an "online platform" within the meaning of Article 3(i) DSA: the user-storage surfaces are limited to one-to-one AI assistant sessions and invite-only, closed-membership multi-user chat rooms with end-to-end encryption by default, and there is no public-discovery, public-search, or public-room surface. The online-platform-tier obligations of Articles 19–28 DSA (including the Article 20 internal complaint-handling system, the Article 21 out-of-court dispute-settlement obligation, the Article 22 trusted-flagger regime, the Article 24 online-platform transparency-reporting regime, and the Article 28 minor-protection obligations) are not addressed by this process.

The same designated-agent surface also accepts notices under:

• UK Online Safety Act 2023, Part 3 — illegal-content safety duties (sections 9–12), content-reporting duty (section 20) and complaints-procedure duty (section 21), as supplemented by Ofcom's Illegal-Harms Codes of Practice;
• Brazil Marco Civil da Internet Article 19 (post-STF Tema 987 notice-and-takedown default; the prior judicial-order rule survives only for crimes against honour), and Código de Defesa do Consumidor Article 37 (misleading commercial practices on sponsored surfaces, where applicable);
• UAE Federal Decree-Law 34/2021 (Cybercrime — cooperation with competent-authority orders, where AskTilly is reachable from the UAE);
• Australia Online Safety (Basic Online Safety Expectations) Determination 2022, as amended by the Online Safety (Basic Online Safety Expectations) Amendment Determination 2024 (registered 30 May 2024) — complaint-handling and generative-AI reasonable-steps.

Take It Down Act (47 U.S.C. § 223a) — residual coverage. § 223a's platform notice-and-removal regime applies on its terms to "covered platforms" — that is, services that serve the public and either (A) primarily provide a forum for user-generated content, or (B) in the regular course of trade or business publish, curate, host, or make available non-consensual intimate visual depictions. Given the surface posture described above, AskTilly does not squarely satisfy either prong and is on the residual edge of "covered platform" within the meaning of TIDA. Where a TIDA-eligible notice does reach AskTilly, AskTilly accepts and processes it on the hosting-tier track described in § 4 below. The good-faith-statement and signature/identification requirements in § 3(d) and § 3(e) below remain available to a TIDA reporter who wishes to invoke them.

Notices concerning child sexual abuse material are addressed in § 8 below.

3. How to File a Notice

Notices may be filed through either of the following channels:

1. By email to takedown@asktilly.ai.
2. By web form at https://asktilly.ai/api/v1/takedown (HTTP POST; multipart form-data; documented JSON contract at https://auth.asktilly.ai/auth/takedown/openapi.json).

A facially-valid notice includes:

1. Identification of the offending content — for example, the room identifier and message identifier, the conversation identifier, or sufficient description for AskTilly to locate it. AskTilly does not operate a public-share or public-link surface, so URLs to user content are not generally available; reporters who possess a copy of the content (for example, a screenshot taken inside an invite-only room) may attach it.
2. A description of the alleged offense under the relevant statute (for example: non-consensual intimate imagery, including AI-generated digital forgeries; defamation; election-period misinformation in covered jurisdictions; hate speech in covered jurisdictions; child sexual abuse material, which is escalated under § 8 below). Notices alleging trademark or copyright infringement may be submitted through this surface, but AskTilly's response to those notices is governed by separate intellectual-property procedures (including, where applicable, notice-and-takedown under 17 U.S.C. § 512 of the Digital Millennium Copyright Act and Article 17 of the EU DSM Copyright Directive 2019/790) and is not addressed by this published process.
3. The reporter's full name and a working email address at which AskTilly may correspond.
4. A good-faith statement of accuracy that the information in the notice is accurate to the best of the reporter's knowledge and belief, and that the reporter is acting in good faith. The Take It Down Act platform-notice provision (47 U.S.C. § 223a) does not itself require this statement to be sworn under penalty of perjury — only that it be a good-faith attestation of accuracy. Where the reporter's jurisdiction or another applicable regime requires perjury wording (for example, 17 U.S.C. § 512(c)(3)(A)(vi) for U.S. copyright notices, or where required by EU Member-State law for DSA Article 16 notices), the reporter is invited to add that wording.
5. For Take It Down Act notices: a physical or electronic signature of the depicted person, the depicted person's authorized legal representative, or a parent or guardian of a minor depicted; identification of the depicted person; and identification of the location of the offending depiction on AskTilly's service (a room identifier and message identifier, or sufficient description for AskTilly to locate it, is preferred). AskTilly does not require, but will accept, a copy of a government-issued photo identification (with sensitive identifiers redacted by the reporter) where the reporter chooses to provide one to expedite identity verification.

A facially-valid Take It Down Act notice has all of items (a) (location of offending content), (c) (reporter contact information), (d) (good-faith statement of accuracy) and (e) (signature, identification of the depicted person, and identification of the location of the depiction); item (b) is also required for non-TIDA notices. The good-faith statement under item (d) satisfies only the statement-of-accuracy component; the other components must also be present for the notice to be facially valid. AskTilly may request additional identity verification before acting on a notice where reasonably necessary. AskTilly does not adjudicate underlying legality; it acts on facially-valid notices in good faith and with reasonable diligence.

4. Acknowledgement and Action Timelines

Stage	Timeline
Acknowledgement of receipt	Within 1 Business Day of receipt at the designated agent or, for notices routed via AskTilly's EU representative, at the EU representative
Substantive disposition of a DSA Article 16 hosting-tier notice	Within 7 calendar days of receipt at the EU representative or the designated agent
Acknowledgement of a counter-notice or appeal	Within 1 Business Day

These timelines are calibrated to the hosting-tier obligations of Articles 11–18 DSA, in particular Article 16 ("timely, diligent, non-arbitrary and objective" treatment) and Article 17 (statements of reasons). AskTilly issues a clear and specific Statement of Reasons under Article 17 to the affected recipient whenever it imposes any of the restrictions enumerated at Article 17(1) (including content removal, visibility restriction, account suspension, monetary-payment restriction, or service termination).

CSAM notices are not deferred to these clocks: § 8 governs and adopts the statutory cadence at 18 U.S.C. § 2258A(a) ("as soon as reasonably possible"). A Take It Down Act-eligible notice (47 U.S.C. § 223a) is processed on the hosting-tier track in this § 4; where AskTilly determines on the facts that a particular item of content places it within the residual scope of TIDA's platform duty, AskTilly will act within the 48-hour TIDA window in addition to this hosting-tier track.

"Business Day" means a day other than a Saturday, Sunday, or public holiday in Italy (for inquiries received by the EU representative) or in the United Kingdom (for inquiries received directly by the designated agent).

Timelines run from the moment of receipt at the designated mailbox or the API endpoint, whichever is earlier. Acknowledgement is sent by automated email containing the notice reference identifier ("display alias") of the form TD-XXXXXXXXXXXX; reporters should cite the display alias in any follow-up correspondence.

5. Counter-Notice and Appeal

A user whose content has been removed may file a counter-notice to takedown@asktilly.ai containing:

• Identification of the removed content (the display alias of the takedown notice if known, or a description sufficient for AskTilly to locate the prior action).
• A statement of the user's basis for disagreement with the takedown.
• The user's full name and a working email address.

AskTilly will acknowledge a counter-notice within 1 Business Day and review it on the same cadence as an inbound notice (see § 4). AskTilly may restore content found in good-faith review to be subject to a meritless or insufficiently-supported takedown notice. Counter-notices do not waive any party's underlying legal remedies between the parties themselves.

6. Privacy of Reporters

AskTilly records, with respect to each notice:

• The reporter's email address.
• The reporter's statement.
• Identity-evidence material submitted under § 3(e), encrypted at rest with server-side KMS encryption, retained per § 7, and accessible only to the designated agent and counsel via short-lived (5-minute) presigned URLs with audit logging of each access.

AskTilly does not log:

• Reporter IP addresses (beyond ephemeral rate-limiter state retained for less than one hour).
• Reporter device fingerprints, cookie identifiers, or browser identifiers.
• Any other reporter telemetry beyond the items above.

7. Retention

Notice records and identity-evidence material are retained for one year from receipt for non-CSAM notices. For notices identifying child sexual abuse material, AskTilly preserves CyberTipline-reported material for at least one year following submission to the CyberTipline, consistent with 18 U.S.C. § 2258A(h) as amended by the REPORT Act of 2024 (Pub. L. 118-59). AskTilly may, at its discretion, preserve such material longer where reasonably necessary to reduce online child exploitation, and must preserve it longer where required by a law-enforcement preservation request. At the end of the applicable retention window AskTilly deletes the identity-evidence material and stamps an audit row reflecting the deletion. Redacted notice metadata (display alias, category, outcome) is retained beyond that point for AskTilly's transparency-reporting obligations.

8. CSAM Escalation

Notices identifying child sexual abuse material are escalated immediately to AskTilly's safety team and reported to the National Center for Missing & Exploited Children CyberTipline under 18 U.S.C. § 2258A. The reporting obligation under § 2258A(a) is triggered by AskTilly's actual knowledge of facts or circumstances from which apparent CSAM is identified, and AskTilly submits the report to the CyberTipline as soon as reasonably possible after that point. Counsel may advise on the report's contents and on accompanying materials, but counsel review does not gate the statutory reporting obligation. AskTilly does not require reporters to provide identity evidence for CSAM notices and applies an expedited internal SLA: immediate priority-1 triage and escalation to the safety team within minutes of receipt. AskTilly preserves CSAM-related material as required by 18 U.S.C. § 2258A(h) — for at least one year following submission to the CyberTipline (REPORT Act of 2024) — and cooperates with law-enforcement preservation requests for additional periods.

9. What This Process Does Not Decide

This published process is not a court of law. AskTilly:

• Does not adjudicate disputes between users or between a reporter and a third party.
• Does not determine whether content is legally defamatory, trademark- or copyright-infringing, or otherwise unlawful as a matter of substantive law.
• Acts on facially-valid notices in good faith and with reasonable diligence; nothing in this process should be read as a concession or stipulation to facts asserted in any notice.

Reporters and counter-noticing users retain all legal remedies they may have against each other and against any third party.

10. Modifications

AskTilly may update this published process. Material changes will be reflected at asktilly.ai/takedown and at its mirror asktilly.ai/takedown.html. The effective date at the top of this notice will be updated to reflect the most recent revision. Notices submitted before a revision will be processed under the version of this process in effect at the time of submission.

11. Contact

Designated agent (notices)	takedown@asktilly.ai
Counsel of record (routing)	legal@asktilly.ai
Privacy office (separate)	privacy@asktilly.ai
Operator entity	Ask Tilly AI Ltd, England and Wales No. 17020603 — registered office: 20 Wenlock Road, London, England, N1 7GU, United Kingdom
Postal (designated agent)	50 Sloane Avenue, London SW3 3DD, United Kingdom
EU representative — Article 27 GDPR	Camerotto Legal — Avv. Maria Allegra Camerotto, Via Santa Margherita 44, 31100 Treviso (TV), Italy — eu-rep@camerottolegal.it — tel. +39 0422 1628816
EU legal representative — Article 13 DSA (hosting-tier obligations under Articles 11–18 only)	Camerotto Legal — Avv. Maria Allegra Camerotto, Via Santa Margherita 44, 31100 Treviso (TV), Italy — dsa-rep@camerottolegal.it — tel. +39 0422 1628816
UK contact (Online Safety Act)	Enrico Ottavian, Director — 50 Sloane Avenue, London SW3 3DD, United Kingdom