Platform Transparency — Ranking, Notice and Content Moderation

Last updated: 05/08/2026

This document sets out the operating rules of the Islania Holistics Platform regarding Practitioner ranking, notice of illicit content and content moderation, in application of:

• EU Regulation 2019/1150 on promoting fairness and transparency for business users of online intermediation services (« P2B »),
• EU Regulation 2022/2065 on a Single Market for Digital Services (« Digital Services Act » or « DSA »).

These documents complement our Terms of Use and our Practitioner Agreement.

1. Single point of contact (DSA arts. 11 and 12)

Any public authority, user, Practitioner or third party wishing to contact the Platform regarding notices, moderation decisions or DSA obligations may reach us at:

• Email address: contact@islaniaholistics.com
• Postal address: Islania Holistics — Route de Limet 10, 4577 Modave, Belgium
• Languages accepted: French, English, Spanish

We commit to acknowledging receipt of any notice of illicit content within a maximum of 48 working hours and to justify any moderation decision (removal, restriction of access, suspension).

2. Notice of illicit content (DSA art. 16)

Any User may notify a content they consider illicit by clicking the « Report » button available on:

• Practitioner pages (public profile),
• Session and course descriptions,
• Public testimonials,
• Forum posts and replies,
• Private messages received (via internal messaging).

Each notice must specify:

• the exact location of the content (URL, document identifier),
• the reason for notice (illicit content, privacy infringement, disinformation, incitement to hatred, copyright violation, etc.),
• the contact details of the notifier if they wish to be informed of follow-up (optional — anonymous notices are accepted).

Handling of notices. Islania's moderation team examines each notice within a period of 7 working days. It may take the following decisions:

• Rejection: the content does not constitute a violation;
• Warning to the Practitioner or User who issued the content;
• Removal of the content;
• Suspension of the account for a determined period;
• Closure of the account in case of serious or repeated breach.

Statement of reasons and appeals (DSA art. 17). Any restriction or removal decision is subject to a written statement of reasons sent to the concerned user. The user may contest the decision by return email to contact@islaniaholistics.com within 30 days. A human re-examination is then carried out by a person distinct from the one who made the initial decision.

3. Ranking parameters for Practitioners (P2B art. 5)

Our public directory of Practitioners (/practitioners) presents active and verified Practitioners according to the following rules:

Main ranking parameters, in decreasing order of importance:

1. Order of registration and activation (main parameter). Each Practitioner receives a static rank upon validation, without algorithmic favoritism. Older Practitioners appear first, except when the criteria below apply.

2. Filters applied by the User: practice language, country, treatment category, keyword. These filters restrict the list but do not modify the relative order within the filtered result.

3. Availability status: Practitioners with at least one available slot in the next 14 days may be visually flagged, but remain ranked according to the main parameter.

No payment modifies the ranking. The Platform accepts no payment, sponsored promotion or financial compensation in exchange for improving a Practitioner's rank. There is no paid "boost" or commercial highlighting of the ranking.

Absence of differentiated treatment. The Platform performs no activity of selling sessions or courses in its own name — it is exclusively a technical intermediary. There is therefore no risk of differentiated treatment between own offerings and Practitioners' offerings (P2B art. 7).

Future modifications. Any substantial modification of the ranking parameters will be subject to a 15-day notice to Practitioners, communicated by email and via this page.

4. Practitioner internal complaint-handling system (P2B art. 11)

The Practitioner wishing to contest a Platform decision (content removal, cancellation sanction, refusal of payout, suspension, non-renewal, etc.) has two paths:

Path 1 — Integrated dispute (for cases provided in site functionalities):

• Abusive cancellation sanction: « Dispute » button in the notification email (48h window with supporting evidence).
• Content removal: reply to the reasoned decision email (30-day window).

Path 2 — Email to contact@islaniaholistics.com for any other dispute. We commit to:

• Acknowledge receipt within 48 working hours;
• Issue a reasoned decision within 10 working days;
• Handle the complaint without discrimination and on an individual basis.

5. Out-of-court mediation (P2B art. 12)

If internal paths fail, the Practitioner may resort to a professional mediator. The Platform offers two independent mediators:

• Belgium: Ombuds Data — Digital dispute mediation service, 15 rue de la Régence, 1000 Brussels.
• European Union (cross-border): Consumer Ombudsman — European Union via the ODR platform (although the European ODR consumer platform was closed in July 2025, it may redirect to sector-specific mediators).

Recourse to a mediator does not preclude bringing the matter before competent courts.

6. Transparency on moderation (DSA art. 15)

The Platform publishes each year a transparency report containing:

• the total number of notices received in the year, broken down by category;
• the number of decisions taken (rejection, warning, removal, suspension, closure);
• the average processing time;
• the number of appeals and their outcome.

The first annual report will be published in Q1 2027 for the 2026 fiscal year.

7. AI processing — non-training and confidentiality

The Platform uses third-party AI services to deliver certain features (navigation help bot, in-course chat, automatic translation of chapters and subtitles, structured PDF extraction of course material, semantic search in the treatments directory). We commit to the following:

Encryption in transit and at rest. All exchanges with these services take place over TLS 1.2 or higher connections (HTTPS). Stored data is on AES-256 encrypted disks on the Firebase Firestore and Cloudflare Stream/Images side.

No data transmitted for model training. We have contractually negotiated with each provider, or verified in their general terms, that transmitted data cannot be used to train their AI models. Providers concerned:

• Cohere Inc. (semantic-search embeddings) — Production API: commitment of non-use of customer data for training.
• Groq Inc. (Llama LLM inference) — Zero data retention: no retention beyond the request, no training.
• Deepgram Inc. (voice transcription) — calls made with the no_storage: true option to guarantee zero retention.
• Modal Labs Inc. (serverless GPU execution of the open-source Kokoro TTS engine) — Modal is a pure stateless execution host: they only have access to punctual calls, train no model and do not retain data beyond execution.
• Google (Gemini via @google/generative-ai) — used only for structured PDF extraction at the time of publication by the Practitioner. This dependency is being replaced by a self-hosted open-source model (Marker). Until this migration, the Practitioner publishing a course is informed at upload and gives explicit consent. We no longer use Gemini for any other processing (embeddings, translations and LLM have been migrated to Cohere and Groq since August 2026).

Sensitive content and health data. Live session transcriptions (produced by Deepgram) and recorded text exchanges (internal messaging, in-session chat) are retained in our databases for the minimum legal duration (see Privacy Policy, section 8), then automatically deleted. They are never transmitted to AI services for training.

Right of access and deletion. Each User may, at any time, request the export or deletion of their personal data from AI subprocessors via the contact form. Deletion propagates to all systems within 30 days.

8. Modifications of this document

This document is likely to evolve according to experience feedback and regulatory developments. Substantial modifications are subject to notification to Users and Practitioners by email, and to a mention at the top of this page.