Digital Services Act statement

1. Who we are

CabDesign is browser software for designing cabinets and rooms and turning them into a saw-ready cut list. StackDesign is browser software for planning tool storage. Both are free to use during our open beta. The same company also runs a custom cabinet shop in the Los Angeles area, which is where the software's knowledge comes from.

2. What kind of service this is, in the Act's terms

The Digital Services Act sorts services into layers, and each layer carries more obligations than the one below it. Here is where we sit and why.

Everything else on this page follows from the third row. We checked it against the software itself rather than from memory before publishing this statement: there is no sharing or publishing feature in the product, and our database rules give a signed-out visitor no access to any user's content at all.

3. Which obligations we think reach us, and which do not

Our view, stated as a view rather than as a ruling anyone has given us, is this.

• The platform obligations do not reach us. Internal complaint handling systems, out-of-court dispute settlement, trusted flaggers, measures against manifestly unfounded notices, advertising transparency, recommender system controls and the protection-of-minors rules all apply to online platforms. We are not one, for the reason in section 2. Separately, the Act exempts micro and small enterprises from that whole set in any case, and we are comfortably a micro enterprise.
• The marketplace obligations do not reach us, because no trader sells anything through our service.
• The transparency reporting obligation does not reach us, because the Act exempts micro and small enterprises from it. It is also worth saying that we would have nothing to report: we have never removed or restricted a piece of user content, because none of it is public and nobody has ever asked us to.
• The general obligations are a question of whether we are in scope at all. The Act reaches providers who offer services in the Union, which means having a substantial connection to it: an establishment there, a significant number of users there, or activities aimed at people there. We have no establishment in the Union, our prices are in US dollars only, our sites are in English only, our address and phone number are in California, and we do no marketing in Europe. Our reading is that we do not currently have a substantial connection to the Union.

We are not relying on that reading to avoid doing anything, which is why sections 4 through 7 exist. A point of contact and a way to report illegal content cost us almost nothing to provide, and a reader in Europe should not have to work out whether we are technically in scope before they can reach us.

4. Our single point of contact

The Act asks in-scope providers to publish a contact point for Member State authorities, the Commission and the European Board for Digital Services, and a separate one for users. We are one small company, so we publish one address for both rather than two that reach the same inbox.

Email is genuinely the fastest route, including for an authority. Post reaches us, but it reaches a working cabinet shop, so it will be slower.

5. Legal representative in the European Union

We have not designated a legal representative in the European Union. The Act requires one from providers of intermediary services who have no establishment in the Union but who offer services there, and our reading, set out in section 3, is that we do not currently offer services in the Union in that sense.

We are stating this rather than leaving it out, because leaving it out is how a reader ends up assuming a representative exists. If our European use grows to the point where we do have a substantial connection to the Union, designating a representative is one of the things that changes, and this section is where we will name them.

Until then, the contact point in section 4 is the way to reach us, and it reaches the people who make the decisions rather than an outsourced desk.

6. Reporting illegal content

There is very little on our service that another person can see, so this section is mostly here for completeness. It still describes what we would actually do, and we would do it whether or not the Act required it of us.

How to report something

Write to support@cabdesign.app for CabDesign, or support@stackdesign.app for StackDesign with the word "report" in the subject line, and include as much of the following as you can:

1. A clear explanation of why you believe the content is illegal, and under which law.
2. Where it is: the exact web address, or enough detail for us to find it.
3. Your name and email address, unless the report concerns child sexual abuse material or one of the other offences where the Act does not ask for them.
4. A statement that you believe, in good faith, that the information in your report is accurate and complete.

A report with a working link and a clear reason is one we can act on. A report with neither is one we will have to come back to you about, which costs both of us time.

What we do with it

• We confirm we received it, without undue delay, to the email address you gave us.
• We assess it ourselves. There is no automated content moderation on our service, and no decision here is made by a machine. A person reads the report and looks at the content.
• We decide: leave it, remove it, restrict access to it, or restrict or end the account behind it. Our Terms of Service and Acceptable Use Policy set out what is not allowed here beyond what the law prohibits.
• We tell you what we decided and why, in plain words.
• Where we restrict something, we also tell the person affected: what we did, why we did it, whether it was because of the law or because of our own terms, and how to challenge it with us.
• Where we learn of information giving rise to a suspicion that a criminal offence involving a threat to someone's life or safety has taken place or is likely to, we will inform the relevant law enforcement or judicial authorities.

Disagreeing with us

If we restricted your content or your account and you think we got it wrong, reply to the message we sent you and say so. A person will look at it again, and if we were wrong we will put it back and tell you. We do not run a formal internal complaint-handling system in the Act's sense, because that obligation applies to online platforms and we are not one. Nothing on this page limits your right to take the matter to a court.

7. Orders from authorities

We comply with lawful orders. If a judicial or administrative authority of an EU Member State sends us an order to act against a specific item of illegal content, or an order to provide specific information about a user, send it to the contact point in section 4 and we will handle it as follows.

• We will confirm receipt without undue delay, and tell the issuing authority what we did and when.
• We will act on the order to the extent it is lawful, properly served, specific about what it requires, and reasoned. An order that does not say what it is about, or that asks us for information we do not hold, will get a reply saying so rather than silence.
• We will tell the affected user that we received the order and what we did, at the latest when we act on it, unless the order or the law tells us not to.
• We will not treat an informal request from anyone, including a law enforcement officer, as an order. If it is an order, it should look like one.

The same applies to lawful process from United States authorities, which is where we are established and where the data sits.

8. Our terms, and how we apply them

The Act asks providers to state the restrictions they impose on the use of their service in clear and plain language, and to apply them diligently and fairly. Ours are in the Terms of Service and the Acceptable Use Policy, both written to be read by a cabinetmaker rather than by a lawyer.

Two things about how we apply them, since this is the honest place to say it. We use no automated content moderation tools, so no account here has ever been actioned by an algorithm. And because nothing users create is public, the realistic reasons we would ever restrict an account are abuse of the service itself, such as attacking our systems or using the AI Designer for something the law prohibits, rather than anything to do with published content.

9. If this changes

The scope call in section 2 depends on a fact about the product: that nothing a user makes here is visible to the public. If we ever add a way to share a design publicly, publish a project, or open a gallery or a template library that other people can browse, we would become an online platform under the Act, and a different set of rules would apply to us. We would rewrite this page before shipping the feature, not after.

The same goes for the scope question in section 3. If we start pricing in euros, translating the sites, or marketing in Europe, we will treat that as the moment we have a substantial connection to the Union, and the legal representative in section 5 comes with it.

The date at the top of this page always shows the current version.