This document is a translation provided for information purposes only. The Romanian version is the sole legally binding version and prevails in the event of any discrepancy.
Article 1. Subject matter and definitions
(1) This document contains the information and procedures required by Articles 11, 12, 16, 17, 18 and 19 of Regulation (EU) 2022/2065 on a Single Market for Digital Services (the "DSA").
(2) This document is also available in Romanian. Communications addressed to KYRO may be written in Romanian or in English.
(3) Capitalised terms have the meaning given to them in Article 1 of the Terms and conditions for clients. For the purposes of this document, "working day" means any day from Monday to Friday, except public holidays in Romania.
Article 2. Service provider
(1) The service provider is to complete: company name, with its registered office at to complete: registered office, Trade Register no. to complete: trade register number, tax identification code (CUI) to complete: tax ID (CUI), EUID to complete: EUID ("KYRO").
(2) The Platform is an online platform within the meaning of the DSA: it hosts and publicly displays Salons' pages, their photos, Clients' Reviews and Salons' replies.
Article 3. Notification to ANCOM
Under Article 5 of Law no. 50/2024, KYRO notifies the National Authority for Management and Regulation in Communications ("ANCOM"), as the Digital Services Coordinator for Romania, at [email protected], within no more than 45 days of the date on which it starts providing the service.
Article 4. Single point of contact for authorities (Article 11 DSA)
Member State authorities, the European Commission and the European Board for Digital Services may contact KYRO by electronic means, as follows:
- a) email address: [email protected];
- b) accepted languages: Romanian and English.
Article 5. Single point of contact for Users (Article 12 DSA)
(1) Users, Salons and any other person may contact KYRO directly and rapidly through the following means:
- a) email address: [email protected];
- b) phone number: to complete: phone;
- c) in the Kyro App and in Kyro Studio, the "Raportează" (Report) button displayed next to each Review, Salon reply, photo, Salon page and Client Rating;
- d) accepted languages: Romanian and English.
(2) Messages are read and answered by a person, not exclusively by an automated system.
(3) KYRO replies to messages within no more than 2 working days of receipt, and to reports of illegal content within no more than 24 hours of receipt.
Article 6. Reporting illegal content (Article 16 DSA)
(1) Content may be reported using the "Raportează" (Report) button in the Kyro App and in Kyro Studio, or by email sent to [email protected]. Where content is reported from the app, the app automatically transmits to KYRO the exact location of the content and the name and email address associated with the Account of the person submitting the report; that person chooses the reason, may explain it in more detail and confirms the good-faith statement.
(2) A report is complete if it contains the following elements:
- a) the reasons: a sufficiently clear explanation of the reasons why the person submitting the report considers the content to be illegal or contrary to the rules of the Platform;
- b) the exact location of the content: the link to the content or, failing that, the Salon, the date and text of the Review, or a description that allows the content to be identified;
- c) the name and email address of the person submitting the report; these details are not required when reporting content that may constitute one of the child sexual abuse offences referred to in Articles 3 to 7 of Directive 2011/93/EU;
- d) a statement by which the person submitting the report confirms a bona fide belief that the information and allegations contained in the report are accurate and complete.
(3) A report is handled according to the following procedure:
- a) KYRO confirms receipt of the report without undue delay, if the person submitting it has provided an email address;
- b) each report is forwarded immediately, by email, to the KYRO team, which examines it diligently, objectively and in a non-arbitrary manner and adopts a decision within no more than 24 hours of receipt;
- c) KYRO informs the person who submitted the report of the decision adopted and of the means of challenging it;
- d) decisions on reports are taken by persons.
(4) The only automated tool used is a filter that rejects, before publication, texts containing profanity or insults included in a predefined list, in Reviews, in Salons' replies, in the comments of Client Ratings and in the texts published by Salons. The author of a rejected text is informed by a message and may rephrase the text. KYRO does not take moderation decisions solely by automated means.
(5) A report addressed to KYRO does not replace a complaint to the authorities. Where content constitutes a criminal offence, the person concerned may also address the police or the public prosecutor's office.
Article 7. Statement of reasons (Article 17 DSA)
(1) Where KYRO removes or restricts content, or suspends or closes an Account, the person affected receives, at the latest on the date on which the measure is applied, a clear statement of reasons, which contains:
- a) the measure adopted (for example, the removal of a Review, the hiding of a photo, the suspension of an Account), its scope and, where applicable, its duration;
- b) the facts and circumstances on which the measure is based, including, where applicable, the fact that the measure was adopted following a report;
- c) information on the use of automated means to detect the content or to adopt the decision; decisions on reports are taken by persons;
- d) in the case of illegal content, the legal ground relied on;
- e) in the case of a breach of the rules of the Platform, the specific rule in the Terms and conditions for clients, in the Terms and conditions for salons or in the Rules on reviews;
- f) the available means of redress: a reply to KYRO's message, following which the decision is reviewed, a complaint to the Digital Services Coordinator, and court action.
(2) A statement of reasons is not sent where the law prohibits it or where KYRO does not hold the contact details of the person affected.
Article 8. Notification of suspicions of criminal offences (Article 18 DSA)
Where KYRO 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, KYRO promptly informs the competent law enforcement or judicial authorities of Romania or of the Member State concerned and provides all relevant information available.
Article 9. Exclusion for micro and small enterprises (Article 19 DSA)
(1) KYRO qualifies as a micro or small enterprise within the meaning of Commission Recommendation 2003/361/EC. Consequently, pursuant to Article 19(1) of the DSA, the obligations laid down in Section 3 of Chapter III of the DSA, including the internal complaint-handling system provided for in Article 20 and the transparency reports of providers of online platforms, do not apply to KYRO.
(2) KYRO complies with the obligation laid down in Article 24(3) of the DSA, which remains applicable, to communicate to the Digital Services Coordinator or the European Commission, at their request, the average monthly number of active recipients of the service.
(3) Although Article 20 of the DSA does not apply to it, KYRO reviews any decision that is challenged, in accordance with Article 12(4) of the Terms and conditions for clients or, for Salons, Article 12 of the Terms and conditions for salons.
Article 10. Complaint to the Digital Services Coordinator
The Digital Services Coordinator for Romania is the National Authority for Management and Regulation in Communications (ANCOM), www.ancom.ro. Any User or Salon may lodge a complaint with ANCOM against KYRO for an infringement of the DSA, in accordance with Article 53 of the DSA.