DMCA Takedown Policy

Last Updated: 15 September 2025

1. COMPANY INFORMATION

Company Name: DIGIFABRICA LTD
Company Number: 15390190
Registered Office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: info@bittenpay.com
Director: Ümit Sönmez

2. INTRODUCTION

This DMCA Takedown Policy establishes DIGIFABRICA’s procedures for responding to copyright infringement claims under the Digital Millennium Copyright Act (DMCA) and equivalent international copyright protection frameworks. While DIGIFABRICA is a UK-based company, we comply with DMCA procedures to facilitate copyright protection for our international users and maintain compliance with global copyright standards.

3. LEGAL FRAMEWORK AND COMPLIANCE

3.1 Applicable Laws

Primary Legal Framework:

UK Copyright, Designs and Patents Act 1988
EU Copyright Directive and related regulations
Digital Millennium Copyright Act (DMCA) procedures
Berne Convention for the Protection of Literary and Artistic Works
WIPO Copyright Treaty and international copyright standards

Safe Harbor Provisions:

Compliance with safe harbor requirements for online service providers
Expeditious removal of infringing content upon notice
Implementation of repeat infringer policy
No actual knowledge of infringing activity
No financial benefit from infringing activity

3.2 DIGIFABRICA’s Role

Platform Status:

Online service provider hosting user-generated content
Digital marketplace facilitating sale of digital products
Intermediary between content creators and consumers
No editorial control over user-uploaded content
Reactive response to copyright infringement claims

4. DESIGNATED COPYRIGHT AGENT

4.1 Agent Information

Designated DMCA Agent:

Company: DIGIFABRICA LTD
Email: info@bittenpay.com
Subject Line: “DMCA Takedown Notice”
Physical Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Phone: Available upon request for urgent matters

4.2 Agent Responsibilities

Duties and Obligations:

Receive and process DMCA takedown notices
Verify notice completeness and validity
Coordinate content removal and user notification
Process counter-notifications and restoration requests
Maintain records of DMCA proceedings
Cooperate with legal proceedings and investigations

5. DMCA TAKEDOWN NOTICE REQUIREMENTS

5.1 Valid Takedown Notice Elements

Required Information (17 USC §512(c)(3)):

Copyright Owner Identification:
- Physical or electronic signature of copyright owner or authorized agent
- Clear identification of the copyright owner
- Contact information including name, address, phone, and email
Copyrighted Work Identification:
- Identification of the copyrighted work claimed to be infringed
- For multiple works, a representative list of such works
- Copyright registration information (if available)
Infringing Material Identification:
- Identification of the material claimed to be infringing
- Specific URLs or location information on DIGIFABRICA platform
- Sufficient information to locate the material
Good Faith Statement:
- Statement of good faith belief that use is not authorized
- Confirmation that use is not authorized by copyright owner, agent, or law
Accuracy Statement:
- Statement that information in notice is accurate
- Statement under penalty of perjury regarding ownership or authorization
Electronic or Physical Signature:
- Physical signature on printed notice, or
- Electronic signature on digital notice

5.2 Notice Submission Guidelines

Submission Requirements:

Submit to designated agent email: info@bittenpay.com
Include “DMCA Takedown Notice” in subject line
Provide all required information in clear, organized format
Use English language for all communications
Include specific URLs or identifiers for infringing content

Supporting Documentation:

Copyright registration certificates (if available)
Proof of copyright ownership or authorization
Examples of original copyrighted work
Previous correspondence with alleged infringer
Additional evidence supporting infringement claim

6. TAKEDOWN PROCESS AND TIMELINE

6.1 Notice Processing Procedure

Step-by-Step Process:

Notice Receipt (0-2 hours):
- Automatic acknowledgment of notice receipt
- Assignment of unique case reference number
- Initial notice completeness assessment
Validity Review (2-24 hours):
- Verification of all required DMCA elements
- Assessment of notice accuracy and good faith
- Legal compliance and completeness check
Content Location (1-4 hours):
- Location of allegedly infringing content on platform
- Verification of content accessibility and status
- Assessment of content nature and infringement claims
Removal Action (1-6 hours):
- Expeditious removal or disabling of access to content
- Preservation of removed content for potential restoration
- System updates and cache clearing
User Notification (1-24 hours):
- Notification to content uploader of removal action
- Provision of takedown notice (with personal information redacted)
- Information about counter-notification process
Complainant Confirmation (1-24 hours):
- Confirmation to copyright owner of action taken
- Provision of case reference number for tracking
- Information about counter-notification possibility

6.2 Processing Timeline

Standard Timeline:

Expeditious Removal: Within 24 hours of valid notice receipt
Emergency Cases: Within 4 hours for urgent copyright violations
Complex Cases: Up to 72 hours for difficult identification or legal issues
Incomplete Notices: 48 hours for clarification request and processing

Timeline Factors:

Notice completeness and clarity
Content identification complexity
Technical removal requirements
Legal consultation necessity
Volume of simultaneous notices

7. DEFICIENT NOTICE PROCEDURES

7.1 Incomplete or Invalid Notices

Common Deficiencies:

Missing required signature or contact information
Insufficient identification of copyrighted work
Vague or unclear identification of infringing material
Lack of good faith or accuracy statements
Improper authorization or ownership claims

7.2 Deficiency Response Process

Clarification Procedure:

Deficiency Identification: Review and identify missing elements
Clarification Request: Contact notice sender within 48 hours
Specific Requirements: Detail exact information needed
Response Timeline: Provide 7 days for clarification response
Final Processing: Process complete notice or close incomplete case

Clarification Communication:

Clear explanation of deficiencies and requirements
Specific instructions for providing missing information
Reference to original notice and case number
Deadline for response and consequence of non-response
Offer of assistance for proper notice completion

8. COUNTER-NOTIFICATION PROCESS

8.1 Counter-Notice Rights

When Counter-Notices Apply:

Belief that material was removed or disabled due to mistake or misidentification
Good faith belief that removal was improper
Content subject to fair use, fair dealing, or other copyright exceptions
Proper licensing or authorization exists for the content
Copyright claims are invalid or unenforceable

8.2 Counter-Notice Requirements

Required Elements (17 USC §512(g)):

User Identification:
- Physical or electronic signature of subscriber
- Full name and contact information
- Username and account information
Content Identification:
- Identification of material removed or disabled
- Location where material appeared before removal
- Specific URLs or platform identifiers
Good Faith Statement:
- Statement under penalty of perjury of good faith belief
- Belief that material was removed due to mistake or misidentification
Jurisdiction Consent:
- Consent to jurisdiction of appropriate federal court
- Agreement to accept service of process from complainant
- Consent to UK court jurisdiction for international users

8.3 Counter-Notice Processing

Processing Steps:

Receipt and Review (1-24 hours):
- Verification of counter-notice completeness
- Assessment of legal compliance and validity
- Assignment of case reference number
Complainant Notification (1-48 hours):
- Forward complete counter-notice to original complainant
- Redact sensitive personal information as appropriate
- Inform of restoration timeline and legal action options
Waiting Period (10-14 business days):
- Monitor for legal action filing by complainant
- Maintain communication with both parties
- Prepare for potential content restoration
Restoration Decision:
- If no legal action filed: Restore content access
- If legal action filed: Maintain removal pending court resolution
- If court order received: Comply with court directives

9. CONTENT RESTORATION PROCEDURES

9.1 Restoration Criteria

Automatic Restoration:

Valid counter-notice received and processed
10-14 business day waiting period expired
No legal action filed by complainant
No court orders preventing restoration

Manual Restoration:

Court order requiring content restoration
Settlement agreement between parties
Withdrawal of original takedown notice by complainant
Determination of improper or fraudulent takedown

9.2 Restoration Process

Restoration Steps:

Restoration Authorization: Confirm eligibility for restoration
Technical Restoration: Restore content access and functionality
User Notification: Inform content owner of restoration
Complainant Notification: Inform original complainant of action
Monitoring: Monitor for potential re-filing of complaints

Post-Restoration Monitoring:

Ongoing monitoring for repeat infringement claims
Assessment of restoration compliance and effectiveness
Documentation of restoration action and rationale
Preparation for potential future disputes

10. REPEAT INFRINGER POLICY

10.1 Repeat Infringer Identification

Tracking and Assessment:

Comprehensive database of infringement notices and responses
Pattern recognition for multiple infringement instances
Cross-reference checking for multiple accounts or identities
Severity assessment and escalation procedures
Regular review of user infringement history

10.2 Repeat Infringer Consequences

Progressive Enforcement:

First Notice: Warning and education about copyright compliance
Second Notice: Account restriction and enhanced monitoring
Third Notice: Temporary suspension and compliance review
Subsequent Notices: Account termination consideration
Severe Cases: Immediate termination for commercial-scale infringement

Termination Procedures:

Thorough review of infringement history and circumstances
Legal consultation for complex cases
Fair notice and opportunity for response
Account closure and content removal
Permanent ban from platform creation of new accounts

11. FALSE DMCA CLAIMS AND ABUSE

11.1 Abuse Prevention

Common Abuse Scenarios:

Fraudulent copyright ownership claims
Competitive use of DMCA to remove rival content
Misuse of DMCA for non-copyright disputes
Automated or mass submission of invalid notices
Retaliatory filing of frivolous takedown requests

11.2 Anti-Abuse Measures

Detection and Prevention:

Verification of copyright ownership claims
Analysis of notice patterns and frequency
Cross-reference checking with known copyright databases
Investigation of suspicious or questionable claims
Legal consultation for potentially fraudulent notices

Consequences for Abuse:

Warning for first-time questionable notices
Rejection of clearly fraudulent or abusive notices
Blocking of repeat abusive notice senders
Legal action for willful misrepresentation under DMCA §512(f)
Cooperation with law enforcement for criminal copyright abuse

12. INTERNATIONAL CONSIDERATIONS

12.1 Cross-Border Copyright Issues

International Users:

Recognition of foreign copyright protections
Compliance with international copyright treaties
Adaptation of procedures for different legal systems
Professional legal consultation for complex international cases
Cooperation with foreign copyright enforcement authorities

12.2 UK and EU Copyright Compliance

European Copyright Framework:

Compliance with UK Copyright, Designs and Patents Act 1988
EU Copyright Directive implementation and compliance
E-Commerce Directive safe harbor provisions
Cross-border enforcement and cooperation procedures
Brexit-related copyright transition considerations

13. TECHNICAL IMPLEMENTATION

13.1 Content Removal Technology

Technical Procedures:

Immediate content disabling upon valid notice
Comprehensive removal from all platform systems
Cache clearing and content distribution network updates
Search index removal and de-indexing
Backup and archival system content removal

13.2 Content Preservation

Evidence Preservation:

Secure storage of removed content for legal purposes
Metadata and access log preservation
Chain of custody documentation
Legal hold procedures for litigation cases
Compliance with data retention and destruction policies

14. RECORD KEEPING AND DOCUMENTATION

14.1 Documentation Requirements

Required Records:

Complete copies of all takedown notices received
Documentation of all actions taken in response
Counter-notices and restoration documentation
Communication records with all parties
Legal consultation and advice documentation

14.2 Retention and Access

Retention Policy:

DMCA-related records retained for minimum 7 years
Legal proceeding records retained indefinitely
Regular backup and secure storage procedures
Access controls and confidentiality protections
Compliance with data protection and privacy laws

15. LEGAL CONSULTATION AND REPRESENTATION

15.1 Legal Support

When Legal Consultation Required:

Complex or unusual infringement claims
Questionable or potentially fraudulent notices
Counter-notice disputes and litigation threats
Repeat infringer policy enforcement
International copyright law questions

15.2 Litigation Support

Legal Proceeding Cooperation:

Evidence preservation and production
Witness testimony and depositions
Expert consultation and analysis
Settlement negotiation and mediation
Court compliance and order implementation

16. USER EDUCATION AND SUPPORT

16.1 Copyright Education

Educational Resources:

Copyright basics and fair use principles
DMCA process explanation and guidance
Best practices for copyright compliance
Counter-notice rights and procedures
Prevention of copyright infringement

16.2 User Support Services

Support Availability:

DMCA process guidance and assistance
Copyright compliance consultation
Technical support for content removal issues
Legal resource referrals and recommendations
Dispute resolution assistance and mediation

17. TRANSPARENCY AND REPORTING

17.1 Transparency Reports

Public Reporting:

Regular publication of DMCA statistics and trends
Aggregate data on takedown notices and responses
Counter-notice and restoration statistics
Repeat infringer policy enforcement data
Platform copyright protection effectiveness metrics

17.2 Stakeholder Communication

Regular Updates:

Copyright holder outreach and education
User community updates on policy changes
Industry collaboration and best practice sharing
Regulatory authority communication and cooperation
Academic and research community engagement

18. CONTACT INFORMATION

18.1 DMCA Agent Contact

Primary DMCA Contact:

Email: info@bittenpay.com
Subject: “DMCA Takedown Notice”
Address: DIGIFABRICA LTD, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

18.2 Counter-Notice Submissions

Counter-Notice Contact:

Email: info@bittenpay.com
Subject: “DMCA Counter-Notice – [Case Reference]”
Include: Complete counter-notice information and case reference

18.3 General DMCA Questions

Support and Information:

Email: info@bittenpay.com
Subject: “DMCA Policy Question”
Response Time: Within 24 hours for general inquiries

19. POLICY UPDATES

19.1 Regular Review

Review Schedule:

Annual comprehensive policy review and update
Quarterly legal compliance and effectiveness assessment
Immediate updates for significant legal or regulatory changes
User feedback integration and policy improvement
Industry best practice benchmarking and implementation

19.2 Change Communication

Update Notification:

30 days advance notice for material policy changes
Clear explanation of modifications and effective dates
Training and education on updated procedures
Transition periods for compliance and adaptation
Ongoing support during policy implementation

20. GOVERNING LAW

This DMCA Takedown Policy operates under UK law while incorporating DMCA procedures for international copyright protection. Disputes will be resolved under English law with recognition of international copyright protections.

21. EFFECTIVE DATE

This DMCA Takedown Policy is effective as of 15 September 2025 and applies to all takedown notices received on or after this date.