Enforcement, Appeals & Account Actions Policy

The purpose of this Policy is to:

• Explain the enforcement tools Helios may use to protect users and the Platform

Establish how Helios may respond to policy violations, fraud risk, payment abuse, unsafe conduct, restricted activity, or other platform risk

• Describe temporary controls, account actions, transaction actions, and other administrative measures
• Explain when and how users may seek reconsideration of certain decisions
• Support fair, risk-based, and operationally effective trust and safety enforcement

Helios may take enforcement or protective action where it reasonably determines that:

• A user has violated the Terms or any Helios policy

An account, listing, transaction, or file creates fraud, safety, legal, payment, privacy, export-control, sanctions, or reputational risk

• Required information is missing, inaccurate, misleading, inconsistent, or unverifiable
• A user is engaging in restricted, prohibited, deceptive, exploitative, or abusive conduct
• Payment providers, financial institutions, legal authorities, or regulators require or expect action
• Immediate action is reasonably necessary to prevent ongoing harm, preserve evidence, protect users, or maintain Platform integrity
• Helios may act with or without prior notice where permitted by law and reasonably necessary under the circumstances.

Helios may impose temporary measures while a matter is being reviewed or where risk containment is reasonably necessary.

Temporary measures may include:

• Listing pauses
• Account review status
• Feature restrictions
• Messaging limitations
• Upload restrictions
• File-access restrictions
• Payout holds or delays
• Transaction freezes
• Reserve requirements
• Reduced profile or listing visibility
• Temporary suspension of certain or all Platform access

Temporary measures do not necessarily mean Helios has reached a final conclusion, but they may remain in place until Helios determines the matter is resolved or sufficiently reviewed.

Where Helios offers payment or payout functionality, Helios may take transaction-related or payout-related enforcement action in response to fraud, payment abuse, compliance risk, safety concerns, chargebacks, restricted activity, or policy violations.

Such action may include:

• Delaying or reviewing payouts
• Holding funds or imposing reserve requirements
• Freezing or reversing transactions where permitted by policy or law
• Restricting transaction functionality
• Requiring documentation before funds are released
• Denying payout access
• Offsetting or recovering amounts owed under applicable policies or agreements
• Helios may coordinate with payment processors or other providers in connection with such actions.

Helios may remove, disable, hide, restrict, or otherwise limit:

• Listings
• Profiles
• Reviews
• Public posts
• Comments
• Uploaded files
• CAD files
• Technical documents
• Images, videos, manuals, or other materials

This may apply where Helios reasonably believes the material violates Platform rules, creates confusion, creates fraud or safety risk, involves restricted activity, misuses private information, or exposes Helios or other users to harm.

• Helios may also require modification or correction of content as a condition of reinstatement.

Helios may suspend an account temporarily where:

• A review is ongoing
• Risk appears credible and unresolved
• A user fails to cooperate with a legitimate review
• A user appears to be evading rules or controls
• The account presents fraud, payment, compliance, security, privacy, or safety concerns
• Temporary removal is reasonably necessary to prevent further harm
• A suspension may be full or partial and may affect all or only certain Platform features.

When deciding what action to take, Helios may consider factors such as:

• The seriousness of the conduct
• Whether the conduct was intentional, repeated, coordinated, or deceptive
• The risk of harm to users or the Platform
• Whether payment, legal, compliance, privacy, or safety concerns are involved
• The credibility and quality of available evidence
• Account history and prior warnings or enforcement
• Whether the user cooperated honestly with review requests
• Whether the issue appears remediable
• Whether legal, payment-provider, or regulatory obligations influence the response
• Helios may weigh these factors differently depending on the nature of the case.

Helios may choose to use escalating measures, but it is not required to provide a warning, temporary suspension, or intermediate action before taking stronger enforcement measures where circumstances justify immediate action.

In serious cases, Helios may immediately remove content, freeze activity, suspend access, terminate accounts, or notify relevant third parties without first issuing a warning.

Helios may consider relationships between accounts when enforcing Platform rules.

Users may not evade enforcement by:

• Creating new accounts after suspension or termination
• Using affiliated or coordinated accounts to continue restricted activity
• Shifting activity to alternate profiles, organizations, or entities for the purpose of avoiding review or enforcement
• Concealing ownership or control of related accounts

Helios may restrict or terminate related accounts where it reasonably believes they are used to evade enforcement or continue abusive conduct.

Helios may retain records relating to enforcement decisions, investigations, user communications, supporting evidence, account history, transaction history, verification materials, and other relevant information for purposes including:

• Trust and safety operations
• Fraud prevention
• Platform integrity
• Legal and compliance obligations
• Appeals and review
• Dispute handling
• Payment-provider requirements
• Prevention of repeat abuse
• Retention may continue after suspension or termination where reasonably necessary.

Where Helios permits reconsideration, a user may submit a request for review of certain enforcement actions.

Helios may decline to reverse or narrow an action where payment-provider, legal, compliance, or fraud-control requirements continue to apply, even if the affected user disputes the decision.

A reconsideration request should include, where applicable:

• The user’s account information
• The decision being challenged
• A clear explanation of why reconsideration is requested
• Any supporting records, clarifications, or corrective information
• Any remedial steps already taken
• Helios may set time windows, formatting requirements, or channel-specific requirements for reconsideration requests.

Helios may decline, limit, or close reconsideration requests that are:

• Repetitive
• Abusive
• Clearly unsupported
• Bad-faith
• Inconsistent with prior verified evidence
• Lacking material new information where such information is needed
• Helios is not required to provide multiple rounds of review or ongoing debate regarding the same decision.

When reviewing a reconsideration request, Helios may consider:

• Whether new relevant information has been provided
• Whether prior evidence was incomplete or misunderstood
• Whether the user has taken meaningful corrective action
• Whether the risk has been reduced or resolved
• Whether legal, payment-provider, or compliance constraints still apply
• Whether reinstatement would create renewed risk to users or the Platform
• Helios may affirm, modify, narrow, or reverse a prior decision in its discretion.

A reconsideration request does not guarantee:

• Reversal of an enforcement action
• Restoration of a listing, file, or review
• Release of held funds
• Reinstatement of payout access
• Full restoration of account functionality
• Restoration of a permanently terminated account
• Helios may condition reinstatement on additional verification, documentation, corrective steps, or ongoing restrictions.

After an enforcement action, Helios may require users to:

• Correct inaccurate information
• Remove or modify problematic content
• Complete verification
• Provide documentation
• Adopt additional safeguards
• Comply with category restrictions
• Refrain from repeat conduct
• Acknowledge or accept new limitations on Platform access
• Failure to comply with reinstatement conditions may result in continued or escalated restrictions.

Where appropriate and legally justified, Helios may share relevant information with:

• Payment processors
• Financial institutions
• Fraud prevention providers
• Hosting or platform service providers
• Regulators
• Legal authorities
• Affected counterparties or rights holders

Such referrals may occur where Helios believes they are reasonably necessary to protect users, comply with obligations, investigate wrongdoing, or respond to legal or payment-related risk.

Conduct that results in enforcement under this Policy may also violate multiple Helios policies. Helios may enforce those policies together rather than separately.

For example:

• Fraud may trigger payout restrictions, suspension, and anti-fraud enforcement
• Privacy misuse may also trigger trust and safety, confidentiality, and account restrictions
• Counterfeit or infringing listings may trigger removal, transaction review, and IP enforcement
• Restricted transactions may trigger compliance review, category bans, and payment controls

Helios may impose enforcement or protective measures where required or reasonably supported by the requirements, restrictions, review outcomes, or compliance expectations of its payment processors and financial service providers, including Stripe, Inc. and its affiliates.

Helios may update this Policy from time to time to reflect changes in law, Platform features, risk patterns, operational needs, or payment and compliance requirements.

When Helios updates this Policy, it will post the revised version on the Platform and update the “Last Updated” date above. Continued use of the Platform after the effective date of an updated version constitutes acceptance of the revised Policy, except where additional notice or consent is required by law.