Digital Services Act (DSA) Transparency

Last updated: February 27, 2026Version: 1.0

Summary

This page explains how Bubba complies with the EU Digital Services Act (DSA). It covers our content moderation approach, how to report illegal content, our complaint and dispute resolution mechanisms, transparency commitments, and our designated contact points.

This page explains how MB Bubba ("Bubba", "we", "us") complies with the Digital Services Act (Regulation (EU) 2022/2065, "DSA"). As an online platform that hosts provider listings and user-generated content (reviews), Bubba is classified as a hosting service provider under the DSA.

  1. Contact Points

1.1 Contact for Authorities (DSA Art. 11)

The designated single point of contact for EU member state authorities, the European Commission, and the European Board for Digital Services:

Emaillegal@bubba.pet
PostMB Bubba, Žirmūnų g. 57-50, LT-09110 Vilnius, Lithuania
Phone+37060569477
LanguagesEnglish, Lithuanian

1.2 Contact for Users (DSA Art. 12)

The designated contact point for users of the Bubba platform, accessible through easy-to-use, direct electronic means:

Emaillegal@bubba.pet
In-appSettings → Help & Support
LanguagesEnglish, Lithuanian

  1. Terms of Service & Content Policies (DSA Art. 14)

2.1 Types of Content on the Platform

Bubba hosts the following types of user-generated and business-generated content:

Content typeCreated byWhere displayed
Provider listingsService providersWebsite, Client app
Service descriptionsService providersWebsite, Client app
Provider profile photosService providersWebsite, Client app
Consumer reviewsPet owners (consumers)Provider profiles (Website, Client app)
Provider review repliesService providersProvider profiles (Website, Client app)
Chat messagesConsumers and providersPrivate chat (visible only to conversation participants)
Types of content hosted on the Bubba platform

2.2 Prohibited Content

Content published on the Bubba platform must not:

a) Be illegal under EU or national law, including:

  • Content that infringes intellectual property rights (counterfeit listings, stolen photos).
  • Defamatory statements — false statements of fact that harm the reputation of individuals or businesses.
  • Content promoting discrimination, hatred, or violence against individuals or groups based on protected characteristics.
  • Content that violates consumer protection law (misleading advertising, deceptive practices).
  • Content that violates data protection law (publishing others' personal data without consent).

b) Violate our Terms of Service, including:

  • Fraudulent or misleading listings (services not actually offered, fake credentials, misleading photos).
  • Spam, unsolicited advertising, or content unrelated to pet services.
  • Fake or incentivised reviews (see our Reviews & Ratings Policy).
  • Harassment, threats, or intimidation directed at any user.
  • Content promoting services that are illegal in the provider's jurisdiction.
  • Impersonation of another individual or business.

2.3 Content Moderation Approach

Bubba applies the following content moderation practices:

  1. Pre-publication checks: Provider listings undergo basic validation (required fields, active account status). Consumer reviews undergo eligibility validation (verified booking, deduplication).
  2. Reactive moderation: Content reported through our notice-and-action mechanism (Section 3) is reviewed by our team. We do not conduct general monitoring of content (DSA Art. 8).
  3. Human decision-making: All decisions to remove, restrict, or disable access to content are made or confirmed by a human member of our team. We do not rely solely on automated tools for content moderation decisions.

  1. Notice-and-Action Mechanism (DSA Art. 16)

3.1 How to Report Content

Any individual or entity can report content they believe to be illegal or in violation of our Terms of Service. You can submit a notice through any of the following methods:

  1. By email: Send a detailed report to legal@bubba.pet.
  2. In-app: Use the "Report" option available on provider listings and reviews (where available).

3.2 What to Include in a Notice

A valid notice should include:

  • Your contact information — name and email address (except for reporting content related to certain criminal offences, where anonymity may be preserved).
  • Identification of the content — a clear description or link to the specific content you consider illegal or violating our terms.
  • Reason for the report — explain why you believe the content is illegal or violates our policies. If alleging a legal violation, please reference the applicable law.
  • A statement of good faith — a declaration that you believe in good faith that the information and allegations in the notice are accurate and complete.

3.3 How We Process Notices

Upon receiving a notice, we follow this process:

StepActionTimeline
1Acknowledgment — We confirm receipt of the noticeWithin 2 business days
2Assessment — We review the reported content against our policies and applicable lawWithin 5 business days (complex cases: up to 10 days)
3Decision — We decide whether to remove, restrict, or leave the content as-isPromptly upon completing assessment
4Notification — We inform both the reporter and the content creator of our decisionWithin 1 business day of the decision
Notice processing steps and timelines

3.4 Expedited Processing

3.5 Bad-Faith Reporting

Individuals who submit manifestly unfounded notices frequently or act in bad faith may have their notice-handling priority reduced or, in extreme cases, may have their notice-submission ability temporarily suspended (per DSA Art. 16(3)).

  1. Statement of Reasons (DSA Art. 17)

When we remove, restrict, or disable access to content, we provide the affected content creator with a statement of reasons that includes:

  • The specific content affected by the decision.
  • The facts and circumstances relied upon in making the decision.
  • The legal or terms basis — a reference to the applicable legal provision or our Terms of Service/content policy that was violated.
  • Whether the decision was triggered by a notice or by our own initiative.
  • Information about redress — how to appeal the decision through our internal complaint mechanism (Section 5) or through out-of-court dispute settlement (Section 6).

Statements of reasons are provided in clear, plain language.

  1. Internal Complaint Mechanism (DSA Art. 20)

5.1 Who Can Complain

The following individuals may file a complaint about a content moderation decision:

  • Content creators whose content was removed, restricted, or whose account was affected.
  • Notice submitters whose notice was declined (i.e., the reported content was not removed).

5.2 How to File a Complaint

Submit your complaint by:

  1. Using the appeal link provided in the statement of reasons notification.
  2. Emailing legal@bubba.pet with the subject line "Content Moderation Appeal" and including:
  • Your account details.
  • The content or notice in question.
  • The reasons you believe the decision was incorrect.

5.3 How Complaints Are Handled

  • Complaints are reviewed by a human team member who was not involved in the original decision.
  • We will issue a reasoned decision within 10 business days.
  • You will be notified of the outcome by email and/or in-app notification.
  • Decisions are not taken solely on the basis of automated means.

  1. Out-of-Court Dispute Settlement (DSA Art. 21)

If you are not satisfied with the outcome of our internal complaint mechanism, you may seek resolution through:

6.1 Certified Dispute Settlement Bodies

You may refer the dispute to a certified out-of-court dispute settlement body under DSA Art. 21. A list of certified bodies is maintained by the Digital Services Coordinator in the relevant member state. We will engage in good faith with any certified body selected by the user.

6.2 Alternative Dispute Resolution

You may also use general ADR mechanisms:

6.3 Courts

You always retain the right to initiate proceedings before the courts of the EU member state in which you are established or resident.

  1. Trusted Flaggers (DSA Art. 22)

Bubba recognises the role of trusted flaggers — entities awarded this status by the Digital Services Coordinator.

  • Notices from trusted flaggers are processed with priority and acted upon without undue delay.
  • We will cooperate with trusted flaggers in a timely, diligent, and non-discriminatory manner.
  • If you are a trusted flagger and wish to establish a working relationship with Bubba, contact us at legal@bubba.pet.

  1. Commercial Communications (DSA Art. 26)

8.1 Provider Listings

Provider listings on Bubba (business profiles, service descriptions, photos, pricing) constitute commercial communications. Each listing clearly identifies:

  • The provider — the business name, location, and contact details are displayed on the provider's profile.
  • The commercial nature — listings are presented in a business marketplace context, making their commercial nature clear.

8.2 Paid or Promoted Listings

Currently, Bubba does not offer paid placement or promoted listings in search results. If this changes in the future:

  • Promoted listings will be clearly and prominently labelled as "Promoted" or "Sponsored."
  • The basis for the promotion (paid placement, partnership, etc.) will be disclosed.
  • Users will be able to distinguish promoted from organic results.

This information is also disclosed in Section 2 of our Business Terms & Conditions in compliance with the P2B Regulation.

  1. Transparency Reporting (DSA Art. 15)

Bubba is committed to publishing annual transparency reports. These reports will include:

  • Orders from authorities: Number of orders received from EU member state authorities (to act against specific illegal content or to provide information), broken down by type and member state, median response time, and actions taken.
  • Notices received: Number of notices submitted through our notice-and-action mechanism, broken down by type, basis, and outcome.
  • Own-initiative actions: Number of content moderation actions taken on Bubba's own initiative, broken down by type and detection method.
  • Complaints: Number of complaints received through our internal complaint mechanism, basis, and outcome.
  • Out-of-court disputes: Number of disputes referred to out-of-court bodies and outcomes.
  • Automated tools: Description of any automated tools used in content moderation, including their purpose, accuracy, and safeguards.

  1. Compliance with Orders (DSA Art. 9-10)

10.1 Orders to Act Against Illegal Content

Upon receiving an order from a competent EU judicial or administrative authority to act against specific illegal content, we will:

  • Process the order without undue delay.
  • Remove or disable access to the specified content within the timeframe set by the authority.
  • Inform the authority of the actions taken.

10.2 Orders to Provide Information

Upon receiving an order from a competent EU judicial or administrative authority to provide specific information about specific users, we will:

  • Comply within the timeframe set by the authority.
  • Inform the authority of the actions taken.
  • Inform the affected user (unless prohibited by the authority for the purposes of preventing, investigating, detecting, or prosecuting criminal offences).

  1. No General Monitoring Obligation

In accordance with DSA Art. 8, Bubba does not impose a general obligation on itself to actively monitor or survey the content uploaded by users. Our content moderation is reactive (responding to notices and reports) supplemented by basic pre-publication validation checks.

  1. Digital Services Coordinator

The Digital Services Coordinator for Lithuania is:

Ryšių reguliavimo tarnyba (Communications Regulatory Authority) Mortos g. 14, LT-03219 Vilnius, Lithuania Website: https://www.rrt.lt

  1. Contact

For any questions about our DSA compliance:

Emaillegal@bubba.pet
PostMB Bubba, Žirmūnų g. 57-50, LT-09110 Vilnius, Lithuania

  1. Related Documents