Schedule 3 to the terms and conditions

Messaging and Moderation Policy

In force from 9 October 2026. This Schedule governs the use of on-site messaging between a registered user and a business listed on NaijaUKHub.

The short version

Messages between you and a business stay on NaijaUKHub, which means there is a record if something goes wrong. They are screened automatically for a list of restricted terms. A person only reads a conversation if it is flagged, if one of you reports it, or if we are required to — not in the ordinary course, and never for advertising. Files you send are deleted after 30 days; the messages stay. Every conversation has a Report button, and it goes to a person.

That summary is for convenience and does not vary the clauses below.

1.Interpretation

1.1
In this Schedule, “the Platform” means the NaijaUKHub website and the services provided through it; “the Operator” means the person or entity operating the Platform; “the Messaging Service”means the facility by which a registered user may exchange messages and files with a business listed in the Platform's directory; “Participant” means a registered user taking part in a conversation through the Messaging Service; “Content” means any message, text, image, document or other material transmitted through the Messaging Service; and “Moderator” means a person authorised by the Operator to exercise the functions described in Part 6.
1.2
This Schedule forms part of the Platform's terms and conditions and is to be read with them and with the privacy policy and prohibited items policy. Where this Schedule and the terms and conditions conflict in relation to the Messaging Service, this Schedule prevails.
1.3
References to legislation are to that legislation as amended, extended or re-enacted from time to time, and include any subordinate legislation made under it.

2.Status of the Messaging Service

2.1
The Messaging Service is a user-to-user service within the meaning of section 3 of the Online Safety Act 2023, and the Operator is accordingly subject to the duties imposed on the provider of such a service, including the illegal content duties and the duties as to content reporting and complaints procedures. The measures set out in this Schedule are the measures by which the Operator discharges those duties, and are intended to be proportionate to the size and nature of the Platform.
2.2
The Operator stores Content at the request of Participants and does not pre-approve it. The Operator's position is that of a hosting provider for the purposes of regulation 19 of the Electronic Commerce (EC Directive) Regulations 2002, and nothing in this Schedule is to be construed as the Operator assuming a general obligation to monitor Content or actively to seek out facts indicating unlawful activity.
2.3
The Operator is not a party to any contract, negotiation or transaction between Participants. The Messaging Service is a means of communication and not an escrow, payment, guarantee or dispute-determination service.

3.Eligibility and acceptance

3.1
Use of the Messaging Service requires a registered account. By sending Content, a Participant accepts this Schedule and warrants that the information given on registration is accurate.
3.2
A Participant must be at least 18 years of age to use the Messaging Service. The Operator may suspend access where it has reasonable grounds to believe this clause is not satisfied.
3.3
A business listed in the directory may disable the Messaging Service in respect of its own listing. Disabling it prevents new Content being sent but does not delete existing conversations.

4.Permitted use

4.1
The Messaging Service is provided for communications reasonably incidental to a listing on the Platform: enquiries as to goods or services offered, their availability, price, delivery and suitability, and the resolution of matters arising from a transaction.
4.2
A Participant must not use the Messaging Service to send unsolicited commercial communications, to advertise goods or services other than those to which the conversation relates, or to collect the personal data of another Participant for any purpose other than the communication in hand.
4.3
A Participant must not represent that the Operator has approved, verified, endorsed or guaranteed any offer made through the Messaging Service.

5.Prohibited Content and conduct

5.1
A Participant must not send Content which is unlawful, or which offers, solicits or facilitates anything unlawful. Without limiting that obligation, Content must not:
1. offer, solicit or arrange the supply of anything listed in the prohibited items policy, whether or not the item itself appears on the Platform;
2. be false or misleading as to a material particular with intent to make a gain or cause a loss, within the meaning of the Fraud Act 2006, including by inducing payment for goods or services which the sender does not intend to supply;
3. amount to a misleading or aggressive commercial practice, or to any practice listed in Schedule 20 to the Digital Markets, Competition and Consumers Act 2024, including the submission or commissioning of false consumer reviews;
4. be used to arrange payment for the purpose of concealing the origin of criminal property, contrary to Part 7 of the Proceeds of Crime Act 2002;
5. constitute harassment within the meaning of the Protection from Harassment Act 1997, or be indecent, grossly offensive, threatening or false such as to engage section 1 of the Malicious Communications Act 1988 or section 127 of the Communications Act 2003;
6. harass a person, or refuse to deal with a person, because of a protected characteristic within the meaning of the Equality Act 2010;
7. be sexual in nature, solicit sexual services, or involve or sexualise a person under the age of 18;
8. facilitate the exploitation of any person, including by way of an offence under the Modern Slavery Act 2015, or involve the retention of another person's identity or immigration documents;
9. seek a password, one-time passcode, banking credential, remote access to a device, or any other information or facility by which unauthorised access to a computer or account might be obtained, contrary to the Computer Misuse Act 1990; or
10. infringe the intellectual property rights or breach the confidence of any person.
5.2
A Participant must not press another Participant to move a negotiation or a payment off the Platform. The Operator records conversations conducted through the Messaging Service and can assist in relation to them; it holds no record of, and can give no assistance in relation to, communications conducted elsewhere.
5.3
A Participant must not upload a file containing malicious code, nor a file whose apparent type differs from its actual content.

6.Screening, review and moderation

6.1
Automated screening. Content is screened automatically against a list of restricted terms maintained by the Operator. Screening does not prevent delivery: a match causes the conversation to be marked for review and notified to a Moderator, and nothing more. No Participant is informed which term, if any, has matched, because disclosing it would defeat the purpose of the measure.
6.2
Review by a Moderator. A Moderator may read the whole of a conversation where, and only where, one of the following applies: automated screening has marked it under clause 6.1; a Participant has reported it under Part 7; a third party has made a complaint identifying it; the Operator is required to examine it by law or by a competent authority; or the Operator has other reasonable grounds to suspect an offence or a risk to the safety of any person. A conversation is not read in the ordinary course, and is not read for any commercial, marketing or profiling purpose.
6.3
Where a Moderator takes part in a conversation, both Participants are notified of that fact and the Moderator's messages are identified as such. The Operator does not participate in a conversation anonymously.
6.4
Action on Content. On obtaining actual knowledge or awareness that Content is unlawful or breaches this Schedule, the Operator will act expeditiously to withdraw it. Withdrawn Content is not deleted: its text ceases to be visible to Participants and is replaced by a notice that a Moderator has removed it, together with the reason. The Operator retains the record of the Content and of the decision taken, so that the action may be reviewed, explained or produced if required.
6.5
Automated screening detects the obvious case and not every case. Content prohibited by Part 5 is prohibited whether or not screening has identified it, and the absence of any action by the Operator is not an endorsement of Content.

7.Reporting and complaints

7.1
Each conversation carries a control by which either Participant may report it to the Operator, giving a short account of the matter complained of. A report may be made at any time and without charge, and it does not close the conversation.
7.2
On receipt of a report the Operator will acknowledge it, examine the conversation under clause 6.2, and take such action under clause 6.4, Part 8 or Part 9 as it considers appropriate. The Operator aims to respond substantively within two business days, and will treat a report disclosing a risk to the safety of a person as a priority.
7.3
A person who is not a Participant, and a Participant dissatisfied with the outcome of a report, may complain to the Operator at contact@naijaukhub.com. A complaint about a decision to withdraw Content, to suspend an account, or to decline to act, will be considered by a person who did not take the original decision where it is reasonably practicable to arrange that.
7.4
Nothing in this Part limits a Participant's right to report a matter to the police, to Action Fraud, to the Information Commissioner's Office, or to any other competent authority, and a Participant is not required to exhaust the Operator's procedures before doing so.

8.Disputes between Participants

8.1
Where a Participant reports a dispute as to a transaction, the Operator may examine the conversation under clause 6.2, record its observations, and make a non-binding statement of what the record appears to show.
8.2
The Operator does not determine disputes, does not act as arbitrator or adjudicator, and does not guarantee any outcome. Rights and remedies as between Participants, including a consumer's rights under the Consumer Rights Act 2015, are unaffected by this Schedule and are to be pursued between them.
8.3
Where a transaction was paid for through the Platform's own checkout, the refund and chargeback provisions of the terms and conditions apply in addition to this Part.

9.Suspension and termination

9.1
The Operator may, on reasonable grounds, withdraw Content, close a conversation to further Content, suspend a Participant's access to the Messaging Service, or suspend or close an account, where a Participant has breached this Schedule or where it is necessary to protect another person.
9.2
The Operator will give the Participant the reason for the action taken and, except where doing so would prejudice the prevention or detection of crime or the safety of a person, will do so at the time the action is taken. The complaints route in clause 7.3 is available in respect of it.
9.3
Closing a conversation does not delete it. Each Participant retains access to the record of what was said.

10.Personal data, retention and deletion

10.1
The Operator is the controller of the personal data processed through the Messaging Service. Its lawful basis for the processing described in Part 6 is its legitimate interests in the safety of users of the Platform, the prevention and detection of fraud, and compliance with the duties referred to in clause 2.1; and, where applicable, compliance with a legal obligation. The privacy policy sets out the remainder of the information required by Articles 13 and 14 of the UK GDPR.
10.2
Messages are retained while the account exists, because they are the record on which a later dispute, complaint or lawful request will turn.
10.3
Files are not. A file sent through the Messaging Service is deleted 30days after it is sent, from both the Platform's database and its file storage. The message to which it was attached remains, marked to show that the file has expired. This limit is applied in accordance with the storage limitation principle in Article 5(1)(e) of the UK GDPR: the Operator has no continuing purpose that would justify holding a Participant's photographs, receipts or statements indefinitely. A Participant who needs a file beyond that period should save their own copy.
10.4
A file is limited to 2MB and to the formats indicated by the composer. The limit is a function of clause 10.3: the Operator holds only what it must, for no longer than it must.
10.5
A request for erasure under Article 17 of the UK GDPR will be given effect so far as it is consistent with the Operator's obligations, including the retention of records necessary for the establishment, exercise or defence of legal claims, or required by law. Where a conversation contains the personal data of another Participant, the Operator will act so as to respect the rights of both.

11.Disclosure

11.1
The Operator may disclose Content and related records to a police force, to another law enforcement or regulatory body, or to a court, where it is required to do so by law, where the disclosure is made under a lawful request or authority (including under Schedule 1 to the Police and Criminal Evidence Act 1984 or Part 3 of the Investigatory Powers Act 2016), or where a disclosure provision in Schedule 2 to the Data Protection Act 2018 applies.
11.2
The Operator may report to the appropriate authority, on its own initiative, Content which it has reason to believe discloses an offence involving the sexual exploitation of a child, trafficking in or exploitation of a person, a threat to the life or safety of a person, or terrorism.
11.3
Except as set out in this Part and in the privacy policy, the Operator does not disclose the contents of a conversation to any third party, and does not sell, licence or otherwise make Content available for advertising or for the training of any system.

12.Liability

12.1
The Operator is not liable for Content sent by a Participant, nor for any loss arising from a transaction or arrangement between Participants, save to the extent that liability cannot lawfully be excluded.
12.2
The Messaging Service is provided on a reasonable endeavours basis. The Operator does not warrant that a message will be delivered without delay, that a notification will be received, or that the Messaging Service will be available uninterrupted.
12.3
Nothing in this Schedule excludes or restricts liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or any other liability which cannot lawfully be excluded or restricted.

13.Amendment, governing law and contact

13.1
The Operator may amend this Schedule. A material amendment will be notified to Participants, and the date at the head of this Schedule will be revised. Continued use of the Messaging Service after an amendment takes effect constitutes acceptance of it.
13.2
This Schedule is governed by the law of England and Wales, and the courts of England and Wales have non-exclusive jurisdiction in respect of it. A Participant resident elsewhere in the United Kingdom may bring proceedings in the courts of the part of the United Kingdom in which they reside.
13.3
Enquiries and notices under this Schedule should be sent to contact@naijaukhub.com.

Annex — legislative framework

The principal enactments to which this Schedule gives effect, and the clause each one bears on. This Annex is explanatory and does not form part of the operative provisions.

Online Safety Act 2023: Imposes the illegal content duties and the content reporting and complaints duties on the provider of a user-to-user service. Parts 6 and 7 of this Schedule are how those duties are met.
Electronic Commerce (EC Directive) Regulations 2002, reg. 19: The hosting provision. It is available only where the provider lacks actual knowledge of unlawful activity or, on obtaining it, acts expeditiously to remove the material — hence clause 6.4.
UK GDPR and Data Protection Act 2018: Governs the processing in Part 10: the lawful basis for moderation, the storage limitation principle behind the 30-day deletion of files, and the disclosure provisions in Schedule 2.
Fraud Act 2006: Fraud by false representation and by failing to disclose information — the offences behind clause 5.1(b) and the screening of advance-fee and non-delivery patterns.
Proceeds of Crime Act 2002, Part 7: Money laundering offences, including arrangements facilitating the acquisition or use of criminal property. The basis for clause 5.1(d).
Digital Markets, Competition and Consumers Act 2024: Replaced the Consumer Protection from Unfair Trading Regulations 2008 with effect from 6 April 2025. Governs misleading and aggressive practices and the banned practices in Schedule 20, including fake reviews.
Protection from Harassment Act 1997: A course of conduct amounting to harassment, including by message. Part of the basis for clause 5.1(e).
Malicious Communications Act 1988, s. 1: Sending an indecent, grossly offensive or threatening communication with intent to cause distress or anxiety.
Communications Act 2003, s. 127: Improper use of a public electronic communications network, including grossly offensive and persistent messages.
Equality Act 2010: Harassment related to, and refusal of service because of, a protected characteristic. The basis for clause 5.1(f).
Modern Slavery Act 2015: Slavery, servitude, forced labour and human trafficking offences. The basis for clause 5.1(h) and for reporting without a request under clause 11.2.
Computer Misuse Act 1990: Unauthorised access to computer material, and supplying articles for use in such an offence. The basis for clause 5.1(i).
Consumer Rights Act 2015: The statutory rights as to goods, services and digital content that clause 8.2 preserves between Participants.
Police and Criminal Evidence Act 1984, Sch. 1: Production orders for special procedure material — one of the routes by which a lawful request for records is made under clause 11.1.
Investigatory Powers Act 2016, Part 3: Authorisations for obtaining communications data. The other principal route engaged by clause 11.1.

Reporting something

Every conversation has a Report this conversation control beneath it. If you cannot reach it, or you are not a Participant in the conversation concerned, write to contact@naijaukhub.com with enough detail to identify the matter.

If you believe a person is in immediate danger, contact the police on 999 rather than us. Suspected fraud can also be reported to Action Fraud on 0300 123 2040.

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