Content Policy

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Version 1 dated September 19, 2025

Introduction

Purpose

At Merlin Software, we are committed to transparent, reliable, and secure communication. This policy describes how we handle content that we publish or host on our digital platforms, in accordance with the Digital Services Act (DSA).

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This policy is part of our Information Security Management System (ISMS) and aligns with processes that comply with the ISO/IEC 27001:2022 standard.

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Framework

Digital Services Act

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Scope of Application

This policy applies to all content published or hosted by Merlin Software via:

Our website: https://www.merlincrisis.com;
Our SaaS solutions: CrisisSuite and the Simulated Media Tool (SMT);
Additional communication channels used to reach large groups, such as email newsletters.

Examples of content:

Web content, product information, blogs, and news articles;
User manuals and knowledge base articles;
Content that has been entered or generated within our platforms, including:
Factual information about (preparation for) crises and incidents, entered and managed by customers in CrisisSuite;
Simulated content, such as training scenarios, messages, or media items in the SMT.

Guidelines for Content Publication

We ensure that content:

Accurate and up-to-date, to the extent that this falls within our responsibility;
It is not misleading, except in the case of simulated content (see below);
Does not contain any illegal or harmful content, such as hate speech, incitement, defamation, or misinformation;
Relevance and function within the context of incident and crisis management,
crisis communication or training.

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Exception for simulated content

CrisisSuite and the SMT may contain intentionally inaccurate or misleading information. This is essential for simulating crisis situations, training crisis response teams, and developing information literacy skills under pressure. Such content is clearly identified within the platform and is exempt from the usual requirements for accuracy and factuality.

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Illegal content

By "illegal content," we mean any information that violates applicable laws or regulations. This may include, for example, statements or materials that are criminal in nature, infringe upon the (property) rights of others, or are otherwise unlawful.

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The assessment depends on the context and relevant legislation (Dutch and European law). In this regard, we follow the definitions set forth in the Digital Services Act and take into account guidance from competent authorities.

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Not all inappropriate or unwanted content is necessarily illegal. However, we can review reports of such content based on this policy and the terms of service for our services.

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Restrictions and measures

If this policy, any laws or regulations, or contractual agreements are violated, we may take action.

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Possible measures include:

The temporary or permanent removal of content;
Temporarily restricting access to certain features;
Suspending or terminating access to the platform or a specific environment.

Measures are always proportionate. The user and/or organization concerned will be notified and may file an objection.

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Management and moderation

The content on our website is published and maintained by authorized staff members.

The following applies to content on our platforms:

CrisisSuite: Merlin Software does not play an active role in moderating factual content, but facilitates reporting and escalation if content appears to violate the law.
SMT: Simulated content can be reviewed automatically or manually if necessary.

All actions related to reports, moderation, and any necessary measures are carried out within the framework of our ISMS.

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Reporting inappropriate or illegal content

Reports can be submitted using the " Report Illegal Content" form.

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This form is also intended for government agencies.

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We will review reports of suspected illegal or inappropriate content within 48 hours. The reporter will receive a confirmation of receipt from us, unless the report concerns criminal offenses related to sexual abuse and no contact information has been provided. The report will then be carefully reviewed by the person responsible within the ISMS. Afterward, the reporter will be informed of the outcome of the report, if possible.

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Please note: If we receive a report indicating that content on our platforms involves (or is suspected of involving) a criminal offense that threatens the life or safety of individuals, we will notify the responsible organization (the client) of this. This does not apply if the nature of the situation indicates that the client is already aware of the matter.

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Transparency in moderation

When content is removed or modified:

We will notify the data subject (if possible), providing a reason and an explanation;
Do we provide an opportunity to object or provide further clarification;
All moderation actions and decisions are logged and retained in accordance with our information security policy, with appropriate access restrictions.

Other complaints or concerns

Complaints regarding our handling of content or moderation decisions (other than formal reports) can be submitted via Contact.

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We take all reports seriously and handle them with care and discretion.

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Processing of Personal Data

We process personal data collected in connection with reports or moderation in accordance with the GDPR. For more information on how we handle personal data, please see our Privacy Statement.

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