Secret - EU Digital Services Act Disclosure

1. Introduction

This disclosure is provided in accordance with the EU Digital Services Act (Regulation (EU) 2022/2065, "DSA"), which establishes obligations for providers of intermediary services in the European Union. Secret qualifies as a provider of intermediary services insofar as it allows users to submit user-generated content (echo text).

Hengtong Li is committed to providing a safe and transparent service for all users within the European Union and the European Economic Area.

2. Service Provider Information

Field	Details
Provider Name	Hengtong Li (individual developer)
Service Name	Secret (iOS application)
Bundle ID	com.lastember.Secret
Contact Email	hengtong.li@foxmail.com
Classification	Micro-enterprise / Hosting service provider (Article 6 DSA)

3. Single Point of Contact

3.1 For EU Authorities and Bodies

In accordance with Article 11 of the DSA, the following point of contact is designated for communication with Member States' authorities, the European Commission, and the European Board for Digital Services:

3.2 For Users (Recipients of the Service)

In accordance with Article 12 of the DSA, users may contact us regarding any DSA-related matters at:

We will acknowledge receipt of communications within 7 business days and provide a substantive response within 30 days.

4. Content Moderation

4.1 User-Generated Content

The only user-generated content on Secret is "echo text" -- optional short reflections (up to 280 characters) that users may submit in response to daily mindfulness prompts. Echo text is associated with anonymous user accounts and is not publicly displayed to other users.

4.2 Content Moderation Policies

Although echo text is not publicly visible, we maintain content moderation practices to ensure our service is not misused for storing or transmitting illegal content. Our content policies prohibit:

• Content that constitutes or promotes illegal activity under EU or Member State law
• Content that incites violence, hatred, or discrimination
• Child sexual abuse material (CSAM)
• Terrorist content
• Content that infringes intellectual property rights
• Content that violates the privacy or dignity of others

4.3 Content Moderation Practices

We employ the following content moderation measures:

• Character limitation: Echo text is limited to 280 characters, reducing the potential for harmful content.
• Reactive moderation: We investigate and take action on reported content.
• Automated detection: Basic automated filtering may be applied to detect clearly illegal content patterns.
• Human review: Reported content is reviewed by a human moderator (the developer).

4.4 Content Moderation Decisions

When content is found to violate our policies or applicable law, we may take the following actions:

• Remove the specific content
• Issue a warning to the user
• Suspend or terminate the user's access to the service

Affected users will be informed of any content moderation decision and the reasons for it, in accordance with Article 17 of the DSA (Statement of Reasons).

5. Reporting Illegal Content

5.1 Notice and Action Mechanism (Article 16 DSA)

Any individual or entity may notify us of the presence of content they consider to be illegal. To submit a notice of illegal content, please send an email with the following information:

5.2 Required Information for Notices

In accordance with Article 16(2) of the DSA, a valid notice should contain:

1. A sufficiently substantiated explanation of the reasons why you allege the content is illegal
2. A clear indication of the exact electronic location of the content (e.g., user ID, date of submission)
3. Your name and email address (except for notices relating to offences involving sexual exploitation of children)
4. A statement confirming your bona fide belief that the information and allegations are accurate and complete

5.3 Processing of Notices

Upon receiving a valid notice:

• We will send an electronic confirmation of receipt without undue delay
• We will process the notice in a timely, diligent, non-arbitrary, and objective manner
• We will inform the notifier of our decision and the available redress mechanisms
• If the content is found to be illegal, it will be removed expeditiously

6. Internal Complaint-Handling (Article 20 DSA)

Users affected by content moderation decisions may submit a complaint within 6 months of the decision. Complaints should be sent to hengtong.li@foxmail.com with the subject line "[DSA - Complaint]".

We will:

• Process complaints in a timely and non-discriminatory manner
• Reverse decisions where the complaint reveals the decision was unjustified
• Inform the complainant of the outcome and the possibility of out-of-court dispute settlement

7. Out-of-Court Dispute Settlement (Article 21 DSA)

Users who have exhausted the internal complaint mechanism may seek resolution through a certified out-of-court dispute settlement body in accordance with Article 21 of the DSA. We will engage in good faith with any certified body selected by the user.

8. Transparency

8.1 Service Description

Secret is a mindfulness application that delivers daily observation prompts. It is not a social media platform, marketplace, or communication service. User-generated content (echo text) is private and not shared between users.

8.2 Algorithmic Systems

Secret does not use recommender systems, algorithmic amplification, or personalized content curation based on user profiling. Daily Secrets are delivered uniformly to all users (adjusted only for timezone and locale).

8.3 Advertising

Secret does not display advertisements. We do not use targeted advertising, behavioral advertising, or any advertising whatsoever.

8.4 Transparency Reporting

As a micro-enterprise, we are exempt from certain transparency reporting obligations under Article 15(2) of the DSA. However, we commit to providing information about content moderation activities upon reasonable request from authorities.

8.5 Platform Size

The average number of monthly active recipients of Secret in the European Union is significantly below 45 million. Secret qualifies as a micro-enterprise within the meaning of the DSA and is therefore exempt from certain obligations applicable to larger platforms.

9. Cooperation with Authorities

In accordance with Article 18 of the DSA, we will cooperate with orders from judicial or administrative authorities of EU Member States, including:

• Orders to act against illegal content: We will act upon receiving valid orders to remove or disable access to specific illegal content.
• Orders to provide information: We will provide information about specific users as required by valid orders, in accordance with applicable data protection law.

We will inform the issuing authority of the effect given to the order, specifying the action taken and the timeline.

10. Legal Representative (Article 13 DSA)

As a micro-enterprise within the meaning of the Annex to Commission Recommendation 2003/361/EC, Secret is exempt from the obligation to designate a legal representative in the EU pursuant to Article 13(2) of the Digital Services Act. Notwithstanding this exemption, users and authorities in any EU Member State may communicate with us in English at the email address provided above.

11. Terms and Conditions

In accordance with Article 14 of the DSA, information about any restrictions we may impose on the use of our service in relation to user-generated content is set out in our Terms of Service, specifically in Section 5 (User-Generated Content) and Section 7 (Acceptable Use).

12. Updates to This Disclosure

This disclosure will be updated as necessary to reflect changes in our practices or in the regulatory framework. The "Last Updated" date at the top of this page indicates when this disclosure was last revised.

13. Contact

For any questions regarding this DSA disclosure or our compliance practices: