DMCA Notice and Takedown Policy

Effective date: 5 May 2026. Last updated: 5 May 2026.

This policy describes how SPOTMIND HK Limited (Business Registration No: XXXX), a company incorporated in the Hong Kong Special Administrative Region ("Spotline", "we", "us") responds to notices of claimed copyright infringement under the United States Digital Millennium Copyright Act, 17 U.S.C. § 512 ("DMCA").

Spotline is a privacy network. Spotline functions as a transitory digital network communications provider under 17 U.S.C. § 512(a) — the "mere conduit" safe harbor — and does not host, cache, store, or curate user-uploaded content. We do not operate a content-sharing platform.

Because Spotline does not store user-uploaded material, takedown notices directed at hosted content (under 17 U.S.C. § 512(c)) are generally not actionable on our network. We nevertheless maintain a designated agent and a repeat infringer policy in compliance with 17 U.S.C. § 512(i), and we respond to validly issued subpoenas and court orders.

In accordance with 17 U.S.C. § 512(c)(2), Spotline has designated the following agent to receive notifications of claimed infringement:

Designated Agent: [DMCA_DESIGNATED_AGENT_NAME]

Service Provider: SPOTMIND HK Limited (operating the Spotline service)

Address: [SPOTMIND_HK_BR_ADDRESS]

Email: dmca@spotline.space

Phone: [DMCA_AGENT_PHONE]

This agent is registered with the United States Copyright Office under the Designated Agent Directory at https://dmca.copyright.gov/.

To submit a notice of claimed infringement under 17 U.S.C. § 512(c)(3), the notice must include all of the following:

(a) a physical or electronic signature of a person authorised to act on behalf of the owner of an exclusive right that is allegedly infringed;

(b) identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;

(c) identification of the material that is claimed to be infringing or to be the subject of infringing activity, with information reasonably sufficient to permit Spotline to locate the material;

(d) information reasonably sufficient to permit Spotline to contact the complaining party — including a postal address, telephone number, and an email address;

(e) a statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorised by the copyright owner, its agent, or the law; and

(f) a statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorised to act on behalf of the owner of an exclusive right that is allegedly infringed.

Notices should be sent to dmca@spotline.space. Notices that fail to substantially comply with the requirements above may not be actionable.

If you believe that material was removed or disabled by mistake or misidentification, you may submit a counter-notification under 17 U.S.C. § 512(g)(3), including:

(a) your physical or electronic signature;

(b) identification of the material that has been removed or disabled and the location at which it appeared before removal or disablement;

(c) a statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification; and

(d) your name, postal address, telephone number, and a statement that you consent to the jurisdiction of the federal district court for the judicial district in which your address is located, or, if outside the United States, the United States District Court for the Northern District of California, and that you will accept service of process from the person who provided the original notice or an agent of that person.

Counter-notifications should be sent to dmca@spotline.space.

In accordance with 17 U.S.C. § 512(i)(1)(A), Spotline has adopted a policy of terminating, in appropriate circumstances, the accounts of subscribers who are repeat infringers.

For the purposes of this policy, a "repeat infringer" means an account that has received three (3) or more independent and substantively compliant notices of claimed infringement within a rolling twelve (12) month period, where each notice has not been withdrawn, retracted, or successfully counter-notified.

Termination under this policy is at Spotline's sole discretion. No refund of any unused subscription period will be issued upon termination for repeat infringement.

Under 17 U.S.C. § 512(f), any person who knowingly materially misrepresents that material or activity is infringing, or that material or activity was removed or disabled by mistake or misidentification, may be liable for damages, including costs and attorneys' fees, incurred by the alleged infringer, by any copyright owner or the copyright owner's authorised licensee, or by Spotline.

Spotline responds to validly issued subpoenas under 17 U.S.C. § 512(h) and to other lawful court orders. Our procedure for handling lawful requests is described in our Privacy Policy.

Spotline does not voluntarily produce subscriber identifying information without a valid subpoena, court order, or other binding lawful process.

Spotline may modify this policy from time to time. Material modifications will be posted on this page with at least thirty (30) days' advance notice. Continued use of the service after the effective date of a modification constitutes acceptance of the modified policy.

This policy implements the United States DMCA. It does not limit or replace any rights or remedies available under the law of any other jurisdiction. Where the laws of another jurisdiction apply, Spotline will respond in compliance with applicable lawful requests received in that jurisdiction.

For DMCA notices: dmca@spotline.space.

For non-DMCA abuse reports: abuse@spotline.space.

Registered office: SPOTMIND HK Limited, Hong Kong SAR.