Moderation & Transparency

Last updated: September 17, 2026

This notice sets out how content in the Valora community is moderated, how content and decisions may be reported or contested, and which points of contact apply. It is published to satisfy the information duties applicable to hosting and community services, including Articles 11, 12, 14, 16, 17 and 18 of Regulation (EU) 2022/2065 (Digital Services Act) and Law No. 5651.

1. Who we are

Provider: Krayir Labs.
Service: Valora: Portfolio Tracker, including its investor community ("Social").
Contact: help@krayir.xyz
Language of correspondence: English.
Enterprise category: Krayir Labs is a micro enterprise within the meaning of Article 19 of the Digital Services Act.
Establishment: Krayir Labs is established in Türkiye and has no establishment in the European Union. The servers holding community data are located in Germany.

2. Scope: the community is a feature of the app

Social is an ancillary feature of the Valora portfolio application. It is tied to the assets and portfolios tracked in the application, it is accessible only to authenticated users within the application, and it cannot be used as a separate service, a website or a standalone social network. The principal purpose of the application is portfolio tracking; the community exists so that users may discuss the assets they follow.

3. Points of contact

A single electronic point of contact is available to users, authorities and any party wishing to report illegal content: help@krayir.xyz. Correspondence is accepted in English and is answered from the same address. No automated tool is required in order to contact the provider.

Authorities are requested to state the legal basis of the request, the content or account concerned and an address for the reply. Orders to act against illegal content and requests for information are handled as described in section 8.

4. Rules that apply to content

The applicable rules are published in the Community Guidelines and form part of the Community Terms, which every user accepts before creating a community profile. They address the subject matter of the community, market integrity, advertising, AI-generated content, conduct, fraud and privacy. Restrictions imposed on user content are limited to those set out in the rules and are applied diligently, objectively and proportionately.

5. How moderation works

Automated tools are combined with human review. Automated means are applied to every post, comment, image and profile detail:

Text: rule-based checks for clear fraud and unlicensed advisory patterns, plus a machine-learning classifier for abusive, misleading or sexual text. Text is also checked in the language it was written in.
Images: sanitisation (metadata removal, re-encoding), a machine-learning risk score for sexual and violent imagery, recognition of text inside images so that the text rules apply there too, and matching against known illegal images. Images are not viewed by a person as part of this automated step: it works on scores and numerical representations.
Child sexual abuse material: the image delivery provider (Cloudflare) scans images against hash lists of known material. A match is reported to the competent bodies and the account is suspended.
Spam and duplicates: repeated or near-identical posts and artificial engagement are detected automatically.
Links: links are not actionable in the community; they are rendered as plain, inactive text.

An automated decision may withhold a post before publication, remove it, or place an account under review. Every such decision is queued as a case for human review; a moderator may confirm or reverse it, and a reversal restores the content and lifts the measure. Content is not reviewed in its entirety before publication, and no general monitoring obligation applies.

6. Measures we can take

Removal of content or reduction of its visibility in respect of a post, comment, image or profile detail.
Review hold: the account may not publish or interact until the review is completed; reading the community remains possible.
Read-only measure for a defined period: no publication, commenting, liking, voting, following or reporting.
Suspension of access to the community, whether temporary or permanent.
Notification of the authorities where required by law.

The measure is selected according to the gravity of the infringement and whether it is repeated. Serious infringements, including market manipulation, fraud, content involving minors and serious threats, may result in permanent suspension without a prior warning.

7. Statement of reasons

Where a measure is applied to a user's content or account, the user receives a notification in the application. Unless disclosure is prohibited by law, the notification states:

the measure taken (removal, reduced visibility, review hold, restriction or suspension) and the content or account concerned;
its duration;
the reason category, for example suspected fraud, misleading financial content, harassment or hate speech, sexual content, violent content, spam, impersonation, or another violation of the community rules;
whether automated means were used in the detection or the decision;
the rule of the community guidelines or the legal provision on which the decision is based;
the means of redress, including the right to bring proceedings before the competent courts.

8. Reporting illegal content and other violations

In the application: every post and comment provides a Report option. The reporting party selects a reason and may add a brief explanation.

By email: any party, including persons without a Valora account, may report content to help@krayir.xyz. Reports should include:

the reasons why the content is considered illegal or contrary to the rules;
the location of the content (the handle of the author and, where available, a screenshot or the exact text);
the name and email address of the reporting party, except where the report concerns child sexual abuse material or another offence and the reporting party wishes to remain anonymous;
a statement that the report is submitted in good faith and is, to the best of the reporting party's knowledge, accurate and complete.

Receipt is confirmed, the report is examined without undue delay in a timely, diligent, non-arbitrary and objective manner, a measure is applied where justified, and the reporting party is informed of the outcome and of the available means of redress. Where automated means were used in the handling of a report, the response states this. Manifestly unfounded or abusive repeat reports may be disregarded.

Orders from authorities: orders issued by courts and competent authorities, including removal and access-blocking decisions under Law No. 5651, are acted upon, and the issuing authority is informed of the action taken. Where content indicates a threat to the life or safety of a person, the competent law enforcement or judicial authorities are informed without delay.

9. Appeals and redress

Every decision notification in the application contains an appeal option, which may be used within six months.
Appeals are decided by a human moderator and not by an automated system, and the appellant is informed of the result.
Where a decision is found to be incorrect, the content is restored and the measure is lifted.
Recourse to the competent courts remains available at all times, as does recourse to any competent out-of-court dispute settlement body.
As a micro enterprise, Krayir Labs is exempt from the obligation to operate a formal internal complaint-handling system (Article 19 of the Digital Services Act); the appeal procedure described here is provided voluntarily.

10. Records we keep

Moderation records: the detection, the automated scores or rules that triggered it, the decision, the moderator who confirmed it and the time of the decision.
Reports: the report, its handling and the response provided to the reporting party.
Acceptance of the terms: the user, the version, the language, a hash of the exact text displayed, the platform, the application version and the time. This record is retained as evidence for up to ten years after deletion of the account.
Removed content: retained only for as long as required for the appeal period, a legal obligation or a dispute.

The processing of personal data is described in the Community Data Notice.

11. Transparency reporting

As a micro enterprise, Krayir Labs is exempt from the periodic transparency reporting obligations and from the obligation to publish average monthly active recipient figures (Article 19 of the Digital Services Act). Should Valora exceed that threshold, the report will be published on this page.

12. Users and authorities in the European Union

Users and authorities in the European Union may contact Krayir Labs at help@krayir.xyz in English. Requests from authorities of the Union are answered at that address and are dealt with in a spirit of cooperation. Should a legal representative in the Union be appointed, the name and address of that representative will be published on this page.

13. Changes

This notice is updated when the moderation system or the applicable legal framework changes. The date shown above indicates the current version.

Reporting illegal content: reports may be sent to help@krayir.xyz — an account is not required in order to submit a report.