Version: 0.2.0 (draft) · Effective: upon publication
This Takedown Policy explains how rights-holders can notify Sazalem of content on the Service that they believe infringes their copyright, trademark, right of publicity, performer's rights or other intellectual-property right, and how creators can respond. It implements the Republic of Kazakhstan Law "On Copyright and Neighboring Rights" № 6-I dated 10 June 1996 and aligns operationally with the safe-harbor standards used by major international platforms.
Capitalized terms not defined here have the meaning given in the Terms of Service.
1.1. Web form (preferred): `/legal/copyright`.
1.2. Email: copyright@sazalem.com — only PGP-signed messages or messages from a verified email of the rights-holder are processed without additional verification.
1.3. Postal: SerikB LLC, State of California, United States of America (Licensor) — please also cc Sazalem LLP / ТОО «Сазалем», Republic of Kazakhstan (Local Operator) (please cc the email channel; postal-only notices are processed but slower).
1.4. Through Abyroy: members of «Әбырой» may submit notices via Abyroy's collective enforcement channel; we will process such notices on the same timeline as direct notices, with the additional benefit of Abyroy's verification of membership and rights status.
A valid takedown notice ("Notice") must contain all of the following:
(a) Your full legal name, postal address, telephone number and email address; (b) If you are acting for a rights-holder, the rights-holder's identification and a statement of your authority to act (power of attorney, label representation, distributor agreement, estate appointment, etc.); (c) Identification of the work allegedly infringed (title, author, year, ISRC/ISWC where applicable, and at least one authoritative reference such as a registration number or a published recording); (d) Identification of the allegedly infringing material on the Service with sufficient specificity for us to locate it — preferably a direct URL or the song_id, artist_id or playlist_id; (e) The specific rights you assert (e.g. master-recording right, composition right, lyrics right, sample, cover-art copyright, trademark, name and likeness, performer's right); (f) A statement that you have a good-faith belief that the use of the material in the manner complained of is not authorized by the rights-holder, its agent or the law; (g) A statement that the information in the Notice is accurate and, under penalty of perjury, that you are authorized to act on behalf of the rights-holder; (h) Your physical or electronic signature.
A Notice that is missing any of the above will be returned with a "needs info" status. We will not act on the Notice until the missing information is supplied.
| Step | Target | |------|--------| | Acknowledgment of receipt | within 24 hours | | Triage (valid / needs info / clearly invalid) | within 48 hours | | Action on a valid Notice (unlist or remove) | within 72 hours of validation | | Notice to the affected creator | at the same time as removal | | Counter-notice window | 14 calendar days from notice to creator | | Restoration if no counter-action by claimant | within 10–14 business days after counter-notice |
We will act earlier than the targets above where required by law, by court order or by an active risk to the catalogue.
4.1. Where the Notice is valid on its face, we will (a) unlist or remove the identified content from public-facing surfaces, (b) notify the affected creator, (c) record the Notice in our enforcement log, and (d) suspend monetization of any associated royalties pending resolution.
4.2. We may, at our discretion, take broader action if the same account is the subject of multiple valid Notices in a short time: suspension of new uploads, payout hold, or escalation under the repeat-infringer policy in §8.
5.1. The affected creator may file a counter-notice within fourteen (14) calendar days of being notified.
5.2. A valid counter-notice must contain:
(a) Your full legal name, postal address, telephone number and email address; (b) Identification of the material that was removed and the location at which it appeared before removal; (c) A statement under penalty of perjury that you have a good-faith belief that the material was removed as a result of mistake or misidentification; (d) A statement that you consent to the jurisdiction of the courts of the Republic of Kazakhstan and that you will accept service of process from the claimant or the claimant's authorized agent; (e) Your physical or electronic signature.
5.3. We will forward the counter-notice to the original claimant.
5.4. If the claimant does not, within ten (10) to fourteen (14) business days of receiving the counter-notice, notify us that they have filed a court action seeking an order against the creator, we will restore the content.
5.5. Restoration does not remove the takedown event from the creator's history; the underlying claim may still be pursued in court.
6.1. False Notices. Knowingly material misrepresentation in a Notice (whether of authority, of ownership, or of the alleged infringement) is a violation of this Policy and may expose the claimant to civil liability for damages caused to the affected creator and to Sazalem (including legal costs and lost royalties).
6.2. Sanctions for abuse. We may (a) refuse to process further Notices from a claimant who has repeatedly filed unfounded Notices in bad faith, (b) require additional verification before processing future Notices from that claimant, (c) refer the matter to law-enforcement, and (d) where the claimant is a Sazalem user, treat the conduct as a violation of the Acceptable Use Policy.
6.3. Right of action. Nothing in this Policy limits any party's right of action under Kazakh law.
7.1. Trademark. A trademark Notice must additionally identify the registration (or, in the case of an unregistered mark, the basis for common-law rights) and the territory of registration. We will assess the claim on the basis of the territories in which the content is distributed.
7.2. Right of publicity / personality rights. A claim that content uses a person's name, image or voice without consent must identify the person and the basis for the right (e.g. the person themselves, an estate, an agent acting under written authority). Voice-cloning claims should reference the Acceptable Use Policy §2.6 and are treated with priority.
8.1. We maintain a record of valid Notices acted on per account. An account that, in our reasonable judgment, has shown a pattern of repeated copyright, trademark or right-of-publicity infringement will be subject to escalating enforcement under the Acceptable Use Policy §6: suspension, then disabling, with permanent blacklist for the most serious or persistent cases.
8.2. We do not publish a fixed numerical "three strikes" rule because the seriousness, source and pattern of strikes vary. Our policy is to act fairly and consistently; the affected creator may appeal under Acceptable Use Policy §7.
9.1. When content is removed under this Policy, future royalties for that content are not generated. Royalties already accrued but not yet paid out for the removed content are held pending resolution and may be (a) released to the creator if the matter is resolved in their favor, (b) released to the claimant if a settlement so directs and the claimant is the verified rights-holder, or (c) released as a court orders.
9.2. Where Abyroy administers the relevant royalties, the §9.1 hold is implemented in cooperation with Abyroy under the Royalty & Payout Agreement.
10.1. We share the Notice with the affected creator. We share the counter-notice with the original claimant. Personal data in those filings is processed under the Privacy Policy and is retained for seven (7) years.
10.2. We do not publicly publish either filings or filer names, save where required by law or court order.
This Policy is governed by the law of the Republic of Kazakhstan. The competent courts of the Republic of Kazakhstan have exclusive jurisdiction over any dispute arising out of or in connection with this Policy or any Notice or counter-notice filed under it, except where applicable mandatory consumer-protection law provides otherwise for the consumer's place of residence.
We may amend this Policy from time to time. Material changes will be notified at least fourteen (14) days before they take effect, except where a shorter period is required by law.
Contact: copyright@sazalem.com (notices), legal@sazalem.com (legal questions), appeals@sazalem.com (counter-notices and appeals)