Legal documentation · loupixa.com
Sanctions & Appeals Policy
Scope & Purpose
This Policy applies to all Clippers and Brand clients who participate in the LoupiXa platform. It governs measures LoupiXa may take in response to non-compliance with the Content & IP Policy, the Disclosure Policy, the Notice-and-Takedown Policy, and the applicable Terms of Service. Acceptance of LoupiXa's Terms of Service constitutes acceptance of this Policy.
General Principles
Sanctionable Violations
| Violation | Policy reference | Presumptive response |
|---|---|---|
| Failure to include a compliant disclosure mention | Disclosure Policy Art. 3 | Strike 1 — Strike 2 if uncorrected within 24h |
| Use of unlicensed third-party content in a paid campaign | Content & IP Policy Arts. 4 & 5 | Strike 1 — immediate exclusion if manifest or deliberate |
| Failure to provide proof of rights within 48h of a formal request | Content & IP Policy Art. 9 | Payment suspension; Strike 1 if persistent non-response |
| Failure to remove content following a formal takedown decision | Notice-and-Takedown Policy Art. 7 | Strike 2 — immediate exclusion if deliberate refusal |
| Submission of false or inaccurate information to LoupiXa | Terms of Service; applicable law | Immediate exclusion |
| Artificial inflation of view counts or engagement metrics | Content & IP Policy Art. 5.4 | Immediate exclusion + forfeiture of all payments |
| Deliberate circumvention of disclosure or compliance requirements | Disclosure Policy Art. 7.4 | Immediate exclusion |
| Publication of prohibited content | Content & IP Policy Art. 5 | Immediate exclusion |
| Brand instructing a Clipper to suppress disclosure | Disclosure Policy Art. 6.2 | Campaign suspension; MSA termination in serious cases |
| Brand providing false rights warranties in a CCP | Content & IP Policy Art. 7.1 | Campaign suspension; indemnification claim; MSA termination in serious cases |
Strikes Framework
Strikes are cumulative across all campaigns and all violation categories. They are not reset between campaigns or at the start of a new calendar period.
A formal written warning is issued identifying the specific violation and required corrective action. The Clipper must complete a compliance acknowledgement before participating in further campaigns. Payment for the non-compliant content is withheld pending correction and re-verification.
Payment for the non-compliant content is permanently forfeited. The Clipper is suspended from all active and pending campaigns for 30 days. Re-admission requires written acknowledgement of this Policy and LoupiXa's express written approval.
The Clipper is permanently removed from the LoupiXa network. All pending payments for non-compliant content are permanently forfeited. The Clipper's account is blocked from re-registration. This decision is final subject only to the appeals procedure in Article 6.
Immediate and permanent exclusion, without prior warning, for: manifest copyright infringement, fraud (fake views, bot inflation, misrepresentation of rights), deliberate refusal to remove content following a formal takedown decision, deliberate circumvention of the disclosure obligation, or publication of content in the Prohibited Content categories.
Payment Consequences of Sanctions
| Scenario | Payment consequence |
|---|---|
| Strike 1 — content pending correction | Payment withheld pending correction and re-verification. If correction is verified, payment is released in the next payment cycle. Failure to correct within 24 hours triggers escalation to Strike 2 for disclosure violations. Failure to correct within 7 days triggers permanent payment forfeiture. |
| Strike 2 | Payment for the non-compliant content permanently forfeited. Payments for compliant content in the same campaign are not affected. |
| Strike 3 / Permanent exclusion | All pending payments for non-compliant content permanently forfeited. Payments for compliant content already verified prior to the decision are released. |
| Immediate exclusion — fraud / deliberate infringement | All pending payments frozen. Following internal review, non-compliant content payments permanently forfeited. Compliant content payments assessed individually. |
| Payment suspension pending investigation | Precautionary measure. Released if investigation concludes in Clipper's favour; forfeited if violation is confirmed. |
Appeals Procedure
Any Clipper or Brand who has received a sanctions decision may appeal through LoupiXa's internal mechanism, in accordance with DSA Article 20.
Grounds for appeal
How to lodge an appeal
Appeals must be submitted in writing to rights@loupixa.com, subject: "Appeal — [reference number]", within 10 working days of receipt of the sanctions notification. The appeal must include: the reference number; grounds; supporting evidence; and a declaration of accuracy.
Processing
| Acknowledgement | Within 24 hours of receipt |
| Decision | Within 7 working days |
| Reviewer | A person not involved in the original sanctions decision |
| Outcome — upheld | Sanction reversed or modified; payment consequences adjusted; compliance record updated. |
| Outcome — rejected | Original decision confirmed with statement of reasons; further redress options communicated. |
| Effect during appeal | Sanctions remain in effect unless LoupiXa determines a suspension is appropriate pending the outcome. |
Where an appeal is rejected, the affected party may refer the matter to ARCOM (competent Digital Services Coordinator — arcom.fr) or to any competent court with jurisdiction over the dispute.
Reinstatement Following Suspension
A Clipper suspended under Strike 2 may apply for reinstatement upon expiry of the 30-day period by submitting a written request to rights@loupixa.com, subject: "Reinstatement Request — [account name]", including written acknowledgement of the violation and steps taken to ensure future compliance. Reinstatement is at LoupiXa's sole discretion. LoupiXa will respond within 7 working days.
A Clipper excluded under Strike 3 or immediate exclusion is not eligible for reinstatement. The decision is final subject only to the appeal procedure in Article 6.
Measures Applicable to Brand Clients
| Violation | Measure |
|---|---|
| CCP found to contain unlicensed content | Immediate campaign suspension. Brand required to provide replacement rights-cleared content within 48h. Indemnification obligations apply. |
| Instructions to Clippers to suppress disclosure | Immediate refusal to transmit the instruction. Formal written warning. Campaign suspension in serious cases. |
| Failure to notify LoupiXa of a known third-party claim | Indemnification obligation triggered. Campaign suspension pending resolution. |
| Repeated or serious violations of the Terms of Service | Termination of the Master Service Agreement. All outstanding invoices remain due and payable. |
Contact
| Appeals submissions | rights@loupixa.com — subject: "Appeal — [reference number]" |
| Reinstatement requests | rights@loupixa.com — subject: "Reinstatement Request — [account name]" |
| Sanctions queries | rights@loupixa.com — subject: "Sanctions Query" |
| General contact | contact@loupixa.com |
| Postal address | 47 rue Vivienne, 75002 Paris, France |
| Acknowledgement — appeals | Within 24 hours |
| Decision — appeals | Within 7 working days |
| Decision — reinstatement | Within 7 working days |
| ARCOM (DSA coordinator) | arcom.fr |