HOSTING ABUSE AND CONTENT COMPLAINT PROCEDURE

Effective Date: 01 February 2026

Applicable To: All clients, partners, licensees, resellers and authorised shared-service operators using Fludnox hosting, email, DNS, content-delivery or infrastructure services.

This Hosting Abuse and Content Complaint Procedure (“Procedure”) governs the submission, assessment and handling of reports concerning suspected unlawful, infringing, abusive, harmful or prohibited activity involving services supplied by The Xdemór Group Limited under the Fludnox brand.

In this Procedure, “You” and “Your” refer to the business, organisation or professional using the Services. “Fludnox”, “We”, “Us” and “Our” refer to The Xdemór Group Limited acting under the Fludnox brand. “Complaint” means a report submitted under this Procedure. “Reported Content” means the website, file, communication, domain, account, application, service or activity identified in a Complaint.

1. Application and Contractual Status #

1.1 Incorporation #

This Procedure forms part of the contractual framework governing the Services and applies together with the Shared Services Terms of Service, the Fludnox Hosting Acceptable Use Policy, the Fludnox Domain Registration Agreement, the Shared Services Data Processing Agreement and the applicable Order Form or Individual Agreement.

This Procedure explains the operational handling of Complaints. It does not create an independent cause of action, require Fludnox to determine a final legal dispute or displace any applicable court, regulator, Registry, Registrar or statutory procedure.

1.2 Client Responsibility #

The Client remains responsible for its Content, users, downstream clients and any reporting or complaints procedure required for a service that it operates.

Where the Client operates a user-to-user service, search service, marketplace, forum, file-sharing service, communication platform or other regulated service, this Procedure does not replace the Client’s own legal and regulatory obligations.

1.3 No Routine Pre-Approval #

Fludnox does not routinely pre-approve or continuously review all Client Content.

The technical availability of Content does not mean that Fludnox has approved its legality, accuracy, safety, ownership or compliance with third-party rights.

2. Matters Covered #

2.1 Abuse and Security Reports #

This Procedure may be used to report phishing, malware, ransomware, credential theft, fraudulent impersonation, unauthorised access, botnets, denial-of-service activity, spam, open relays, compromised accounts, harmful redirects and other conduct prohibited by the Fludnox Hosting Acceptable Use Policy.

2.2 Content Complaints #

This Procedure may also be used for Complaints concerning alleged copyright or trade mark infringement, unlawful disclosure of personal data, defamation, fraud, threats, unlawful goods or services and other allegedly unlawful Content hosted through the Services.

2.3 Matters Outside Fludnox Control #

Fludnox may be unable to act where the Reported Content is not hosted, transmitted, cached, proxied, registered or otherwise controlled through a Fludnox-managed Service.

Where reasonably identifiable, Fludnox may direct the reporting party to the relevant Client, website operator, domain Registrar, Registry, independent platform provider, law-enforcement authority or other responsible organisation.

2.4 Commercial Disputes #

This Procedure is not intended to determine ordinary commercial, contractual, employment, ownership, shareholder, partnership or payment disputes.

Fludnox may decline to intervene where the Complaint concerns competing claims to a business, account, website, domain or asset and no binding legal decision or clear evidence of unauthorised access has been provided.

3. Submission of Complaints #

3.1 Reporting Channel #

Complaints should be submitted through the designated abuse-reporting mechanism available through the Fludnox policy portal.

Where the designated mechanism is unavailable, the Complaint may be submitted to support-fludnox@shared-services.co.

Formal court documents, regulatory notices and legally binding demands must be sent separately to legal@xdemor.com.

3.2 Required Information #

A Complaint must provide sufficient information to identify and assess the Reported Content. It should include:

1. the exact domain, URL, IP address, email header, message identifier, account or other technical location;
2. a clear description of the alleged violation;
3. the date and time at which the activity was observed;
4. available screenshots, logs, headers, files or other evidence;
5. the reporting party’s name, organisation, contact information and relationship to the matter;
   available screenshots, logs, headers, files6. the legal or contractual basis of the Complaint, where applicable; and
6. the action requested.

A general statement that a website or account is “illegal”, “fraudulent”, “offensive” or “infringing” without sufficient supporting information may not be actionable.

3.3 Authority #

A person submitting a Complaint on behalf of another person, company, rights holder or public authority must confirm their authority to act and may be required to provide supporting evidence.

Fludnox may request identity verification where necessary to prevent fraud, impersonation or misuse of the Complaint process.

3.4 Accurate Statements #

The reporting party must act honestly and must not knowingly submit false, materially incomplete, fabricated or misleading allegations.

Submission of a Complaint does not guarantee removal, suspension, disclosure or any other requested result.

4. Initial Assessment #

4.1 Validation #

Fludnox may verify whether the Reported Content is associated with the Services, whether the Complaint contains sufficient evidence and whether the matter falls within this Procedure.

Fludnox may request additional information before beginning or continuing an assessment.

4.2 Risk Classification #

Complaints may be classified according to their apparent severity, urgency, credibility and potential effect on individuals, infrastructure, legal compliance or third-party rights.

Priority may be given to active phishing, malware distribution, account compromise, child sexual abuse material, credible threats to life or safety, ongoing attacks and other matters presenting immediate or serious risk.

4.3 No Admission #

Acknowledging, investigating, forwarding or acting upon a Complaint does not constitute an admission that the Reported Content is unlawful or that Fludnox has liability for it.

5. Urgent Protective Action #

5.1 Immediate Measures #

Fludnox may restrict, isolate, block, redirect, suspend or disable access to the Reported Content without prior notice where it reasonably considers immediate action necessary to address:

1. active phishing, malware, credential theft or system compromise;
2. an ongoing network or denial-of-service attack;
3. child sexual abuse material or apparent child exploitation;
4. a credible and imminent threat to life or physical safety;
5. an urgent court, regulatory, Registry, Registrar or law-enforcement requirement;
6. a serious risk to data integrity, infrastructure or other users; or
7. another comparable emergency.

5.2 Scope of Action #

Where reasonably practicable, Fludnox will limit protective action to the affected Content, account, process, domain, IP address or Service component.

A wider suspension may be applied where the risk cannot be reliably isolated or where continued access could allow the activity to continue.

5.3 Preservation and Reporting #

Fludnox may preserve relevant records and report the matter to an appropriate authority, provider or affected organisation where required or permitted by law.

Fludnox may be prohibited from notifying the Client or reporting party that preservation, disclosure or reporting has occurred.

6. Client Notification and Response #

6.1 Notice to the Client #

Except where immediate action, confidentiality, legal restriction or security risk makes notice inappropriate, Fludnox may notify the Client of a Complaint and provide sufficient information to allow a response.

Personal information, confidential evidence or security-sensitive material may be redacted where disclosure is unnecessary or unlawful.

6.2 Client Response #

The Client must respond within the period specified in the notice and must provide accurate information, supporting evidence and details of any corrective action.

The response period may be shortened where the matter is urgent or extended where the Complaint is complex and continued operation does not create material risk.

6.3 Failure to Respond #

Fludnox may decide the matter on the available information where the Client fails to respond, provides materially incomplete information or does not take required remedial action.

Failure to cooperate may constitute a separate breach of the applicable contractual framework.

6.4 Corrective Action #

Corrective action may include removing or restricting Content, securing an account, changing credentials, patching software, disabling a user, stopping communications, correcting registration data or implementing another appropriate measure.

7. Assessment and Decision #

7.1 Relevant Factors #

Fludnox may consider:

1. the specificity and reliability of the Complaint;
2. the nature and apparent legality of the Reported Content;
3. the evidence provided by the reporting party and Client;
4. the immediacy and seriousness of the alleged harm;
5. applicable legislation, court orders and regulatory requirements;
6. the Hosting Acceptable Use Policy and other incorporated terms;
7. whether the activity is repeated or systemic;
8. the technical ability to isolate the affected material; and
9. the risk of acting or failing to act.

7.2 No Final Adjudication #

Fludnox is not a court and is not required to determine conclusively whether a legal right has been infringed.

Where the dispute requires a legal determination, Fludnox may maintain the existing position, apply an interim restriction or require the parties to obtain a court order, regulatory decision, Registry decision or recognised dispute-resolution decision.

7.3 Available Outcomes #

Fludnox may:

1. reject or close the Complaint;
2. request further information;
3. forward the Complaint to the Client or responsible provider;
4. require remediation;
5. restrict or remove specific Content;
6. block traffic, email or technical functionality;
7. isolate or suspend an account or Service;
8. preserve records;
9. refer the matter to an appropriate authority or provider; or
10. terminate the affected Service under the applicable contractual framework.

8. Intellectual Property Complaints #

8.1 Copyright Complaints #

A copyright Complaint must identify the protected work, the Reported Content, the location of the alleged infringement, the basis on which the reporting party claims ownership or authority and the reason the use is alleged to be unauthorised.

Fludnox may request evidence of ownership, licensing status or authority to act.

8.2 Trade Mark Complaints #

A trade mark Complaint must identify the registered or otherwise protected mark, the relevant jurisdiction, registration details where applicable, the allegedly infringing use and the basis on which that use is claimed to infringe legal rights.

A dispute involving ordinary comparative use, resale, criticism, commentary, domain ownership or competing trade claims may require formal legal determination.

8.3 Client Response #

The Client may provide evidence of permission, licence, ownership, lawful use, exhaustion, exception, defence, misidentification or removal of the affected material.

Fludnox may maintain a restriction while credible competing evidence is reviewed.

8.4 No United States DMCA Procedure #

Unless Fludnox expressly states otherwise for a particular United States service, this Procedure is not a United States Digital Millennium Copyright Act notice-and-counter-notice procedure.

A United States-style counter-notice does not automatically require restoration of Content hosted under a service governed by the laws of England and Wales.

9. Defamation and Reputation Complaints #

9.1 Required Information #

A defamation Complaint should identify the exact words or material complained of, their location, the meaning alleged, why the statement is claimed to be false or defamatory and the serious harm said to have resulted or to be likely to result.

9.2 Website Operator Procedure #

Where Fludnox legally qualifies as the operator of the relevant website for the purposes of section 5 of the Defamation Act 2013, Fludnox may apply the statutory website-operator procedure.

Where the Client or another party operates the website, Fludnox may forward the Complaint to that operator rather than determine the dispute itself.

9.3 Court Determination #

Fludnox may require a court order or other binding decision where the dispute concerns contested facts, opinion, public-interest publication, privilege, identity or another substantive defamation issue.

10. Privacy and Personal Data Complaints #

10.1 Hosted Personal Data #

Where a Complaint relates to personal data controlled by the Client, Fludnox will ordinarily forward the matter to the Client and act in accordance with the Shared Services Data Processing Agreement and the Client’s lawful documented instructions.

Fludnox does not independently determine a data subject request where it acts solely as Processor.

10.2 Independent Controller Processing #

Where the Complaint relates to personal data processed by The Xdemór Group Limited as an independent Controller, it will be handled under the Shared Services Privacy Policy.

Privacy matters may be submitted to privacy@xdemor.com, and matters requiring the Data Protection Officer may be submitted to dpo@xdemor.com.

10.3 Unlawful Disclosure and Immediate Risk #

Fludnox may immediately restrict access to exposed credentials, financial information, intimate material, identity documents or other personal data where continued availability creates a serious and credible risk.

11. Review of a Decision #

11.1 Request for Review #

A reporting party or Client materially affected by a decision may request one internal review by providing the reasons for disagreement and any new evidence.

A review request must be submitted promptly and does not automatically suspend the original decision.

11.2 Review Outcome #

The review may confirm, vary or reverse the original action.

Fludnox may decline repeated review requests that present no materially new evidence or legal basis.

11.3 External Remedies #

Nothing in this Procedure prevents a person from seeking a court order, regulatory determination, Registry or Registrar decision or another remedy available under applicable law.

12. Repeat Violations #

Repeated, deliberate or systemic violations may result in enhanced monitoring, restrictions, suspension or termination.

Fludnox may consider related Complaints across accounts, Services, domains, downstream users or entities under common control where there is reasonable evidence of coordinated or repeated abuse.

A Client must not restore, republish, relocate or redirect to Content that Fludnox has required to be removed or restricted without express written approval or a binding legal determination.

13. Misuse of the Complaint Process #

Fludnox may reject, restrict or report Complaints submitted for harassment, competitive interference, censorship, extortion, impersonation, unlawful disclosure or other improper purposes.

A Client’s submission of knowingly false or abusive Complaints may constitute a breach of the Hosting Acceptable Use Policy.

Fludnox is not required to disclose internal investigation methods, confidential evidence, security controls or information relating to another Client.

14. Records, Disclosure and Confidentiality #

Fludnox may retain Complaint records, communications, logs and evidence for as long as reasonably necessary to investigate the matter, comply with law, establish actions taken or defend legal rights.

Personal data will be processed according to the applicable Controller and Processor roles.

Information may be disclosed to the Client, reporting party, rights holder, infrastructure provider, Registrar, Registry, regulator, court, law-enforcement body or other authorised recipient where required or permitted by law and reasonably necessary for the matter.

15. Resellers and Downstream Services #

A reseller, agency, managed-service provider or shared-service operator must maintain an effective contact and complaint process for its downstream users.

The intermediary must promptly forward relevant Complaints, investigate downstream activity and implement reasonable instructions issued by Fludnox.

Fludnox may communicate directly with a downstream operator or end client where reasonably necessary to address an urgent legal, security or service-continuity risk. Direct communication does not create a separate commercial agreement.

16. Timelines #

Fludnox will handle Complaints according to their urgency, complexity, evidence and technical effect.

No fixed investigation or resolution period applies unless mandatory law, a binding order or an Individual Agreement requires one.

A delay caused by missing information, a third-party response, legal proceedings, technical investigation or the reporting party or Client does not invalidate the process.

17. Notices and Related Documents #

Operational Complaints must be submitted through the designated abuse-reporting mechanism or, where unavailable, to support-fludnox@shared-services.co.

Formal legal notices must be sent to legal@xdemor.com.

This Procedure operates together with the Shared Services Terms of Service, Fludnox Hosting Acceptable Use Policy, Fludnox Domain Registration Agreement, Shared Services Data Processing Agreement and Hosting Migration, Suspension and Termination Procedure.

18. Changes and Governing Law #

Fludnox may amend this Procedure in accordance with the amendment provisions of the Shared Services Terms of Service.

Urgent security, abuse-prevention or legally required changes may take effect immediately where permitted by the contractual framework and applicable law.

This Procedure and any non-contractual obligations arising from it are governed by the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction, subject to mandatory law and any independently applicable dispute procedure.