Digital Millennium Copyright Act

DMCA Policy

DMCA REPEAT INFRINGER POLICY

In order to comply with the Digital Millennium Copyright Act (DMCA) requirement that “repeat infringers” be terminated from using Whistle, it is the is the policy of Whistle to handle allegations of alleged infringement as follows:

1. All notices of alleged infringement will be logged in the company’s DMCA Tracking Spreadsheet, and the notices will be saved in internal records.  
2. The URL of the removed content, the name/user ID of the individual believed to have posted the content, and other applicable information, will be logged in the DMCA Tracking Spreadsheet.
3. A pdf copy of the allegedly infringing content will be created and saved in internal records and the content will be promptly removed from the applicable website.
4. If the complaint is the first one received applicable to an individual, the company will send that individual a notice regarding the allegation of infringement, as well as a warning that if the individual engages in further alleged infringement, his/her user account with Whistle will be terminated.
5. Upon receipt of a second allegation of infringement applicable to the same individual, the individual’s account with Whistle will be terminated, and the individual will be notified of this termination.

The legal department of Whistle may, in its discretion, determine if exceptions should be made to this policy in unique circumstances (e.g. a user’s account may be terminated after only a single infringement).

For clarity, if a single report of infringement includes multiple postings by an individual (e.g. Whistle receives a letter stating that 5 photos have been uploaded by one user) this will be treated as multiple incidents of infringement, even though only one complaint was received.