Takedown and rights-holder policy

DRAFT. Lawyer review pending. Items marked [L] are open questions for the lawyer.

What we collect

We collect only pages that anyone can open without an account. We do not log in to the sites we read, do not use accounts on them and do not solve captchas. Our scrapers are built not to return personal data such as names, email addresses, phone numbers or links to personal profiles.

Who can ask

• The owner or operator of a website we read.
• The holder of rights in content we return, such as copyright or database rights.
• Anyone who finds data about themselves in our output.

How to ask

Email [email protected] with "Takedown" in the subject. Please include:

• the website or the pages concerned;
• what you want us to do: stop collecting, remove specific data, or both;
• who you are and your connection to the site or data (owner, rights holder, the person concerned, or someone acting for them);
• an address where we can reach you.

You do not need a lawyer and you do not need to cite a law. Letters by post go to the address in our legal notice. [L1]

What we do

1. We confirm that we received your request, within one working day.
2. If you own or operate a site and ask us to stop, we stop collecting from it within 24 hours of your request. We take the scrapers for that site out of our catalogue, stop runs in progress and remove sample data from our website. We do not ask you to prove your case first. [L2]
3. If you find data about yourself, we remove it from results we still hold and fix the scraper so it does not return that data again.
4. We tell you in writing what we did.

We may ask questions to understand the request, but that never delays stopping collection from your site.

What we cannot remove

Results that our customers already downloaded are on their own systems. We tell customers who ran the affected scraper in the last 7 days that the source was withdrawn. [L3]

Coming back

We do not start collecting from a site again after a takedown unless the owner agrees in writing, or our lawyer advises that a specific concern does not apply and we have told you first. [L4]

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Questions for the lawyer

Remove this section and every [L] marker before publishing.

• [L1] Do we need a postal address for notices or a named contact person? Is a single email address enough for DSA Art. 11-12 style points of contact, and does the DSA apply to us at all?
• [L2] Is withdrawing on any request within 24 hours, without checking the requester's authority, wise? It costs little and stops escalation, but a competitor could abuse it to remove sources from our catalogue.
• [L3] Do we owe our customers anything (notice, refund, a duty to delete) when a source is withdrawn after they downloaded results? Should the Terms require customers to delete data on request?
• [L4] Under what conditions may we restart collection after a takedown request that we think is unfounded?