Content Moderation Policy

1. Introduction

1.1 Purpose

This Policy establishes the standards and procedures for all Content uploaded to the NEL website or platform by Uploaders.

For the purposes of this Policy:

"Content" means any material uploaded, submitted, published, or otherwise made available through the NEL platform in any format, including but not limited to courses, lectures, podcasts, audio-visual media, images, downloadable resources, live-streamed sessions, interactive materials, written posts, comments, and any other user-generated material, whether in text, audio, visual, or multimedia format.

"Uploader" means any individual or entity who uploads, submits, or otherwise makes Content available on the NEL platform, including but not limited to employees, independent contractors engaged by NEL, content creators, guest contributors, co-producers, and any third party granted upload access to the platform.

1.2 Scope

This Policy applies to all Uploaders globally. All Uploaders are required to comply with the laws of the United Arab Emirates (UAE) and the regulations of SHAMS (Sharjah Media City). Where an Uploader is based in a jurisdiction whose laws impose additional or stricter obligations in respect of content moderation, data protection, or consumer protection, the Uploader is solely responsible for ensuring compliance with those local laws.

1.3 Governing Law and Jurisdiction

This Policy, and any dispute or claim arising out of or in connection with it (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the UAE and the Emirate of Sharjah. The parties irrevocably submit to the exclusive jurisdiction of the courts of the Emirate of Sharjah in respect of any such dispute or claim. Notwithstanding the foregoing, NEL reserves the right to seek injunctive or other equitable relief in any jurisdiction where it considers it necessary to protect its rights or the integrity of its platform.

Notwithstanding the above, NEL will comply with UK's Online Safety Act (OSA), the European Union's Digital Services Act (DSA), Australia's Online Safety Act 2021, and Singapore's Online Safety (Miscellaneous Amendments) Act and such other legislation as applicable from countries where subscribers access the Content.

1.4 Amendments

NEL reserves the right to review, update, or amend this Policy at any time. Uploaders will be notified of material changes to this Policy through a notice published on the NEL platform, with not less than fourteen (14) days' notice prior to the amended Policy taking effect, except where an immediate amendment is required by applicable law or regulation, in which case NEL will provide notice as soon as reasonably practicable.

2. Integrity, Copyright & AI Disclosure

2.1 Originality

All Content must be original or otherwise lawfully licensed. Uploaders must not incorporate any third-party intellectual property — including copyrighted works, trademarks, trade names, logos, or other proprietary material — into their Content unless they hold a valid, written, and subsisting licence from the relevant rights holder that expressly permits use of such material in the manner in which it is used within the Content. Uploaders must be able to produce evidence of any such licence upon NEL's request.

Each Uploader shall indemnify, defend, and hold harmless NEL and its affiliates, directors, officers, employees, and agents from and against any and all claims, losses, damages, liabilities, costs, and expenses (including reasonable legal fees) arising out of or in connection with any allegation or finding that the Content infringes any laws, including without limitation the intellectual property rights of any third party.

2.2 Fair Use

Foreign "Fair Use" standards do not apply on this platform. Uploaders must not rely on the fair use doctrine or any equivalent foreign doctrine when determining whether their use of third-party copyrighted material is permissible on the NEL platform. Uploaders remain solely responsible for ensuring that all Content complies with applicable copyright and intellectual property laws.

2.3 AI Disclosure

Where any element of Content has been created or materially assisted by Generative AI (including AI-generated scripts, images, audio, voiceovers, video, synthetic voice replication or voice cloning), this must be disclosed clearly at the start of the Content description.

AI-generated Content that depicts a real, identifiable individual saying or doing something they did not say or do is prohibited (i.e. Deepfakes), unless the individual has given prior written consent or the Content is unambiguously labelled as satire at the outset (while remaining subject to the aforesaid disclosure).

2.4 Strike

Any violation of this Policy, as determined by NEL, shall be considered a "Strike". Upon the occurrence of a Strike, NEL may, in its absolute discretion, elect to suspend upload privileges of the Uploader (for such time as it deems appropriate) or permanently ban the Uploader from the NEL platform. Notwithstanding the foregoing, NEL reserves the right to immediately remove any Content at any time in its absolute discretion.

3. Prohibited Content

In accordance with international best practices and UAE laws and regulations, Content must NOT:

• Offend Religion: Content must not insult, mock, or vilify Islam, other divinely revealed religions, or their adherents.
• Insult National Symbols: Criticise the UAE President, Rulers of the Emirates, the Flag, or the National Anthem.
• Harm Social Cohesion: Content must not promote sectarianism, tribalism, racism, or discrimination on the basis of religion, ethnicity, or national origin, or contain material likely to disrupt public order, public safety, national unity, or the UAE's foreign relations.
• Violate Privacy and Data Protection rights: Content must not feature or identify any individual without their prior, explicit, written consent. Uploaders are solely responsible for obtaining and retaining records of all necessary consents.
• Promote Illegal & Harmful Acts: Content must not promote, glorify, facilitate, incite or depict any of the following: bullying, harassment, or hate speech targeting any individual or group; violence, terrorism, or violent extremism; sexually explicit or obscene material (pornographic materials); animal cruelty; the use, sale, or distribution of controlled substances or illegal drugs; the promotion of tobacco or vaping products in a manner targeting minors; pyramid schemes, unlicensed investment schemes, or any unauthorised financial promotion (get rich schemes); or any other activity that is illegal under applicable UAE law or any other applicable jurisdiction.
• Spread Misinformation: Content must not present false or unverified information as fact where doing so is likely to cause harm, endanger public health or safety, damage the UAE's economic or judicial systems, or otherwise constitute a rumour or "fake news".
• Violate applicable law: Content must not violate any applicable law, including without limitation, laws relating to cybercrime and intellectual property and any regulatory standards.
• Constitute Unauthorized Professional Advice: Content must not purport to provide legal, medical, healthcare, psychological, investment, financial, tax or other regulated professional advice unless the Uploader is appropriately qualified, licensed and legally authorised to provide such advice in the relevant jurisdiction. Educational, informational and academic discussions are permitted, provided they are not presented as a substitute for professional advice.

4. Commercial Transparency & Advertising

4.1 Disclosures

All paid promotions, sponsorships, gifted products, and affiliate links must be disclosed clearly. For written or descriptive Content, the tag "#AD" or "#Sponsored" must appear at the very beginning of the Content description. For audio or audio-visual Content, a verbal disclosure of advertisement or sponsorship must be made at the very beginning of the Content.

4.2 Licensing

Uploaders who conduct commercial advertising or brand partnerships through the NEL platform may be required to hold a valid personal media licence under applicable law and must obtain prior written approval of NEL. Uploaders are solely responsible for obtaining and maintaining any such licence and all costs associated to such licence.

5. Child Safety & Age Rating

5.1 Content Classification

Uploaders are responsible for accurately classifying their Content at the point of upload. Content that contains material unsuitable for persons under the age of 18 must be tagged as "18+" or "Adult Only" using the classification tool provided on the NEL platform.

NEL reserves the right to independently review and re-classify any Content where NEL considers that the Uploader's classification is incorrect or inadequate. Where NEL re-classifies Content as 18+ or Adult Only, the Uploader will be notified in writing.

5.2 Child Protection

Child sexual abuse material and any content that sexually exploits, endangers, or harms minors is absolutely prohibited on the NEL platform. Uploaders must strictly adhere to applicable child rights / protection laws. Uploaders and users who become aware of such content must report it to NEL immediately at [email protected].

6. Moderation & Enforcement

6.1 Right of Takedown

NEL reserves the right to remove any Content immediately and without prior notice in its absolute discretion and accepts no liability in this respect.

For the avoidance of doubt, NEL does not author or endorse Uploader content and accepts no liability for it, to the fullest extent permitted by applicable law.

6.2 AI Assistance

NEL reserves the right to use automated tools, including AI-based systems, to detect, review, and moderate Content.

6.3 Personal Data and Privacy Compliance

Where Content contains personal data or information relating to an identified or identifiable individual, the Uploader represents, warrants and undertakes that:

• (a) such personal data has been collected, processed and disclosed lawfully and in compliance with all applicable data protection, privacy and cybersecurity laws;
• (b) all necessary consents, notices, permissions and legal bases for processing and publication have been obtained and documented;
• (c) the Content does not unlawfully disclose sensitive personal data, confidential information or information protected by legal or contractual confidentiality obligations; and
• (d) the Uploader shall promptly provide evidence of such consents, notices, permissions or legal bases upon request by NEL.

The Uploader shall indemnify and hold harmless NEL from and against any claims, regulatory investigations, fines, penalties, liabilities, losses, costs or expenses arising from any breach of this Section.

7. General Provisions

7.1 If any provision of this Policy is found to be invalid, unlawful, or unenforceable under applicable law or regulation, that provision shall be severed from this Policy to the minimum extent necessary to remedy such invalidity or unenforceability.

7.2 NEL does not guarantee distribution, visibility, or monetisation of any Content.

7.3 To the fullest extent permitted by applicable law, NEL (including its officers, directors, and affiliates) shall not be liable for any indirect, incidental, special, consequential, or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data, or other intangible losses.

7.4 NEL acts as an intermediary service provider and assumes no responsibility or liability for the accuracy, legality, or appropriateness of any Content uploaded.

7.5 NEL reserves the right to retain Content, metadata, and associated Uploader data even after its removal from public view or the termination of an account for legal, regulatory, and investigative purposes.