Complaints, AI moderation and human review

Loocas plans an AI agent to handle reports and complaints about reviews. No real case processing by an AI provider, paid appeal service or related billing is active in the current version.

This framework supplements the review charter and reporting procedure. It must be implemented through technical rules, controls, contracts and human resources before launch. It guarantees neither absolute truth nor error-free AI.

A review author, merchant, brand or other affected person may request examination of content by providing its reference, URL, specific grounds and useful evidence. The initial submission, examination and notification of the first decision are intended to be free of charge.

Supporting material must be proportionate and relevant. A low rating, negative opinion, commercial relationship or paid subscription is not grounds for removal. Product and seller reviews remain separate; a delivery dispute must not transfer a seller’s reputation to a product.

A request that already challenges a decision must be classified before routing. If it falls within a remedy requiring free human review, that process applies from this request; calling it an “initial complaint” does not allow an AI-only decision or a charge for access to a human.

Where legally permissible and sufficiently documented, the agent may decide to retain the review, remove it or request clarification. It will apply published rules to the reference and case evidence: product matching, the relevant experience, duplication, substantiated manipulation or another ground defined in the charter.

An internal confidence score or automated signal alone does not establish that an author is lying. A decision must not depend on whether the review is favourable, a brand’s economic importance or payment for a service. Where evidence is insufficient, the agent requests clarification or refers the case; it does not invent evidence.

Ambiguous legal classification, materially conflicting evidence or a serious risk to an individual’s rights must be referred to a competent human before an adverse measure based on that assessment. Urgent situations and orders from authorities follow the human handling and deadlines applicable to them.

Where a decision falls within Article 22 GDPR because it has a legal effect or similarly significantly affects a person, solely automated decision-making is restricted and must not be presumed permissible. The Loocas framework requires meaningful human intervention before action in such cases, without presuming a legal exception or valid consent.

The reviewer must be able to examine relevant evidence, consider observations and change or reverse the AI’s proposal. A merely nominal approval is insufficient.

The reporting party and affected author will receive appropriate information about the outcome: action, facts relied on, rule applied, scope, any duration, use of AI and challenge routes. Communications will protect private evidence and third-party data, without unnecessarily publishing the reporter’s identity.

The planned audit trail includes the case identifier, relevant sources, dates, rule and model versions, automated steps, human interventions and changes of decision. Accessible explanations concern the reasons useful for a challenge; they do not require disclosure of confidential data or irrelevant internal reasoning.

The selected target is an initial decision or reasoned request for clarification within seven working days after receipt of a complete case. The target for a human review is fifteen working days after receipt of the necessary information. These service targets must be implemented and are not presented as universal statutory deadlines.

Necessary additional information, difficulties or delays must be explained, with follow-up information. No mechanism may selectively delay unfavourable reviews or free cases. Urgency, a mandatory obligation or a deadline set by an authority takes precedence over these targets.

Payment will not be required to exercise a remedy or obtain human intervention that must be free under applicable law. Authors’ and reporters’ requests will be handled according to their respective rights, not only those of the business funding the service.

If Article 20 DSA applies, access to the internal complaint system will be electronic and free for at least six months from notification of the decision. Complaint decisions will be overseen by appropriately qualified staff and will not rely solely on automated means. Applicable out-of-court remedies and access to the courts remain available.

The service’s classification and any exemptions, including those under Article 19 for certain small businesses, must be assessed. They will not be presumed merely because Loocas has recently launched. If there is doubt about whether a case must be free, it will be routed to the free process.

An additional human service may be offered to a business only for a scope separate from remedies and interventions that must remain free. The working price is €49 excluding VAT per case; it remains a commercial proposal to be confirmed in a quotation specifying scope, deliverables and final price.

No order or invoice will be generated simply because someone disagrees, submits a report or reaches the end of a free queue. Express acceptance of the quotation is required. If the request ultimately concerns a remedy that must be free, no fee will be charged for that remedy and an improperly collected amount will be returned.

The service does not purchase removal, a favourable decision or priority that would compromise free complaints. The outcome may be to retain the review. The business may decline the offer without losing its rights or those of the author.

If the assessment establishes an error attributable to Loocas, the fee is refunded in full. A required correction or a free remedy cannot be made conditional on payment for an optional service.

Only data necessary for examination will be used. Private evidence will not be shared with network shops. Submitted text, images and documents will be treated as untrusted evidence to verify, never as instructions authorising the agent to change its rules or access other accounts.

Quality must be assessed on positive, negative and nuanced cases, different languages and product categories. Errors, bias, reversals on appeal and unequal treatment must be monitored; faulty criteria or models must be capable of correction or suspension.

This document does not determine the AI provider, processing locations, subprocessors, retention or reuse rights. GDPR roles, lawful basis, information to individuals, any necessary impact assessment and required agreements must be established before a transfer. Training on case files is not authorised by default.

A revised decision must be reflected in affected displays and aggregates or summaries that used the review. Restoring content requires the same reference, rights and visibility checks as publication. The action and its correction must remain explained to affected people.

For the current marketing website, the public contact is contact@suchetbuttier.com at SUCHET & BUTTIER. The future experience will clearly identify free controls and channels, access to a human and, separately, any optional service. This page does not announce an automated complaint channel as already operational.