EU DSA Transparency Report 2024

ExoClick is an Advertising Network that connects advertisers and publishers through our innovative platform and technology.

In line with our obligations under the European Union (EU) Digital Services Act (DSA), ExoClick is publishing an annual transparency report. These reports describe the efforts and resources that are committed to the moderation of online content in addition to outlining all relatable statistics.

This specific report is for the period covering from the 1st of January to 31st of December 2024.

Advertiser Data

Within this section, we will outline the relevant facts and figures concerning advertising activity across the network.

Number Of Campaigns And Marketing Assets

Below is a summary of the quarterly numbers of all advertising campaigns, advertising display banner creatives, and URLs that were manually reviewed by our compliance team upon submissions by advertisers. There is also a breakdown of how many had been approved by the team compared to those that were declined for not meeting our advertising guidelines and rules.

Number of Illegal Ads Declined

Below is a summary of ads that were declined by our compliance team through complaints that had been received and through investigation were found to be illegal and against our advertising guidelines and rules. The volume is the total covering the full time period of this report.

Average Time Taken To Remove Illegal Ads

The graph below displays the average mean action time (unit is minutes) on investigations relating to any form of illegal activity as far as advertisements are concerned. It outlines the average action time per quarter and the average of the year.

Malvertising / Misleading Ads Volumes Detected

The following graph outlines the number of malvertising ads per month that were either manually detected, reported to us, or detected via the automated ad scanning tool that we utilize to detect and eliminate all forms of malvertising as well as ads that go against the user experience.

Malvertising Detections By Type

The table below shows a breakdown of the types of non-compliant ads that were detected and the amount that types represent.

Account Suspensions

In this section, we outlined the number of accounts that were permanently suspended in the case of banning due to the violation of our guidelines, rules, and terms and conditions within the timeframe of this report.

In the case of a violation we consider severe and take a no-tolerance policy towards, such as the discovery of illegal child exploitation material, the permanent suspension is issued instantly even if this was a first offense.

A total of 107 accounts were permanently suspended from our network in the year 2024.

Malvertising SLA

Our compliance team has an SLA resolution time relating to any malvertising investigations of 30 minutes or less. The graph below indicates the percentage of cases per quarter that were actioned within that SLA time.

Publisher Data

Within this section, we outline the relevant facts and figures concerning publishing activity. These relate to the websites registered to our network who monetize their website traffic through the displaying of ads from advertisers.

Volume Of Websites

The graph below displays the number of new websites approved on our network for monetization per quarter in addition to the number of those declined where they fail to meet our standards, guidelines, and rules.

Number Of Copyright Infringement Cases

This graph displays the number of copyright infringement notifications we have received, per quarter, via various sources such as content owners, internet service providers, or individuals who report their image being used on a website without consent.

ExoClick qualifies as an “Intermediary Service Provider” within the meaning of the U.S. Digital Millennium Copyright Act (“DMCA”) as well as in other regulations such as the Spanish Law of Information Society Services (“LSSI”), and the EU Digital Services Act (“DSA”).

Thus, ExoClick does not host the allegedly infringing material and as a mediator will forward the complaint to the publisher or website owner who has the ability and responsibility to address the request effectively.

Such cases are investigated and actioned in line with these laws.

Number Of CSAM Cases

ExoClick has a zero-tolerance policy towards all forms of child sexual abuse material (CSAM) content and any such content that is found on any publisher’s website will incur a strong response and action. The graph below indicates the number of investigations performed by quarter, where CSAM content was reportedly featured on a publisher’s website.

Government Requests

This section reports data on requests from EU Member State authorities to provide user account information (from advertisers or publishers). ExoClick considers all such requests carefully and fulfills its obligations based on valid legal orders.

ExoClick did not receive any government requests to remove content (illegal ads) or to provide information regarding advertisers’ account information during the reporting period.

Compliance Team Operation

About Our Compliance Team

At ExoClick we have 13 employees working within the Compliance team. They work in-house from our offices in Barcelona, Spain. We do not outsource.

Our compliance team operates on a 24 hours per day, 7 days per week basis to ensure we have round-the-clock protection.

Their roles are varied. It includes reviewing advertisements and publishing websites submitted to our network, liaising with clients relating to compliance matters, performing financial and traffic fraud investigations, fraud prevention, account verification, and KYC as well as investigating advertising abuse and matters relating to illegal activities. Thus reviewing content is only one part of their role.

Training Program

When we onboard new compliance officers, they undergo intensive induction training with the Head of Department, Team Leader, or alternatively the department’s Director.

The training involves the in-depth reading of the theory, information, and team processes contained within our comprehensive intranet, completing various modules, and engaging in practical shadowing sessions. When a minimum level of competency (through testing) is attained they start performing the task under observation, guidance, and with instant feedback.

After the initial induction training period has been concluded, their knowledge building, skill set, and accuracy are improved on an ongoing basis with frequent performance and feedback meetings held on a one-on-one basis as well as at a team-wide level. There is a go-to person on each shift to support and guide them as needed.

State of Employee Wellbeing

As Compliance Officers in their roles may encounter egregious content may be encountered, their health and well-being are of absolute importance to us and as such we have a number of measures that are in place.

This ensures that they remain fresh in each area negating any complacency or fatigue, which ensures whilst additionally ensuring no one performs the same taskmoderates for the entirety of a full day.

Task Rotation

The Compliance Officer role is a varied one.

As such, our Compliance Officers are not reviewing content for the entirety of their shift. Where staff resourcing allows, they are encouraged to rotate between the 3 or 4 core work areas in two-hour cycles, switching tasks after that point. This ensures that they remain fresh in each area negating any complacency or fatigue, which ensures no one performs the same task for the entirety of a full day.

Bi-yearly Health Checks

Twice per year, our Compliance Officers undergo mandatory tests through an external local medical service ASPY (https://www.aspyprevencion.com/ (opens in a new tab)). They are asked a series of questions to determine if there are any potential concerns for our employees with regard to addressing them.

Quarterly in House Questionnaires

All employees within the company who are exposed to sensitive content (this is not only for our compliance team) are sent an in-house questionnaire/survey in relation to the exposure. The results are assessed in-house with any concerns or issues addressed.

121 Session with Therapist/Councillor

We offer all employees access to a therapist via the paid health insurance that we provide.

In House Support, Peers/Managers/HR

ExoClick is a fully collaborative and supportive place to work. There is always someone available whether that is a peer, a manager, or a member of our HR department to provide support, advice, and guidance irrespective of the topic as is required and in a fully confidential manner through various channels such as email, instant messaging, virtual video call or via a physical in-person meeting. We are all here to help and support each other.

Other Initiatives

The physical and mental well-being of our employees is important to us. As such we offer a range of benefits such as free monthly massages, private medical healthcare as well as weekly yoga and meditation classes which anyone can sign up to as is their choice.

Automated Tools

As touched upon above, we utilize the malvertising prevention and ad quality solution provided by https://www.adsecure.com/ (opens in a new tab). This tool scans all advertisements on our network to detect breaches of our advertising guidelines post-approval. This additionally includes automated actions such as automatically declining any malvertisements from the network thus removing some of the manual actions performed by our compliance team.

Content Reporting

Part of the role is to identify and eradicate all forms of illegal content that we may come across. Where this is encountered there is an escalation process in place to ensure the incident is both recorded as such as well as reported to the team management and authorities.

The incident is then further investigated by team management to limit further exposure of the Compliance Officer to egregious content as well as the case assessed for any additional actions that may be required beyond merely declining the content. We take all forms of illegal content seriously and the appropriate levels of actions, depending on the severity level, are taken to ensure network integrity is maintained and the internet in general is safer through our diligence.

CSAM Reporting

We take a zero-tolerance approach towards any form of child sexploitation (CSAM) where encountered. Not only are strict and severe action taken against the perpetrators internally, such cases are reported externally to the Internet Watch Foundation (https://www.iwf.org.uk/ (opens in a new tab)) to whom we have a paid membership to support and aid the great work that they do in this field.

They are a non-profit organization who specialize in this area. All confirmed cases of CSAM are reported to them. They then perform a full investigation with regard to having the content removed from the internet in addition to any other actions such as referring the website to police organizations such as Interpol.

In the event any CSAM case is identified as being in Spain, we escalate the matter via the local reporting system Incibe (https://www.incibe.es/ (opens in a new tab)).

We are also a member of We Protect Global Alliance (https://www.weprotect.org/ (opens in a new tab)) where we engage and implement the learnings that provides guidance on understanding the issue of child sexual abuse online.