Digital Millennium Copyright Act (DMCA) Policy

Updated August 2022


Willis Capital, a proprietary trading product offered by Western Sahara Worldwide Services (WSWS), acknowledges the importance of intellectual property rights and compliance with copyright laws. The Digital Millennium Copyright Act (DMCA) serves as a critical framework for protecting copyrighted material online and outlines procedures for addressing copyright infringement claims. This DMCA Policy aims to establish guidelines and procedures for handling copyright infringement notices, ensuring compliance with the DMCA requirements. The Digital Millennium Copyright Act (DMCA) is a United States copyright law that provides a legal framework for addressing instances of copyright infringement related to digital content. Enacted in 1998, the DMCA includes provisions for online service providers (OSPs) and outlines the process for addressing claims of copyright infringement, including takedown notices and counter notifications.

Scope and Objectives

This DMCA Policy applies to all digital assets, content, and material hosted, managed, or facilitated by Willis Capital as part of its proprietary trading product offerings. It also extends to users, traders, and any individuals interacting with Willis Capital's online platforms.


The primary purpose of this DMCA Policy by Willis Capital is to:

  • Provide a clear and efficient mechanism for addressing copyright infringement claims in accordance with the DMCA guidelines.
  • Establish procedures for handling DMCA notices and counter notifications regarding copyrighted material hosted on Willis Capital's online platforms.
  • Outline the responsibilities and procedures for handling DMCA takedown requests, ensuring prompt and appropriate action in response to valid notifications.
  • Safeguard the intellectual property rights of content creators, authors, and copyright holders.
  • Clearly define the scope and applicability of this policy across Willis Capital's digital platforms, services, and online presence.
Policy Statement
Commitment to DMCA Compliance

Willis Capital, as a proprietary trading product offered by Western Sahara Worldwide Services (WSWS), is unequivocally committed to upholding the principles of intellectual property rights and ensuring compliance with the Digital Millennium Copyright Act (DMCA). We recognize and respect the rights of copyright holders and are dedicated to fostering an environment that values and protects original creative works.

Respect for Intellectual Property Rights

We firmly believe in respecting intellectual property rights and understand the significance of safeguarding copyrighted materials. Willis Capital emphasises the importance of legal and ethical practices concerning copyrighted content and is committed to promptly addressing any alleged copyright infringements on its online platforms or proprietary trading services. As part of our commitment to DMCA compliance, Willis Capital will take necessary and appropriate actions in response to valid DMCA notices, facilitating the protection of copyrighted content while ensuring fair and transparent processes for all involved parties.

Copyright Infringement Notification
Filing a Copyright Infringement Notification

Willis Capital acknowledges the significance of promptly addressing alleged copyright infringements in compliance with the DMCA. To file a copyright infringement notification, please ensure that your notification includes the following:

  • Identification of the copyrighted work: Provide adequate information identifying the copyrighted material that has allegedly been infringed upon, including specific references, titles, or URLs where the material is located.

  • Contact Information: Include your full name, mailing address, telephone number, and email address to enable us to contact you regarding the notification.

  • Statement of Good Faith Belief: A statement affirming that you have a good faith belief that the use of the copyrighted material has not been authorised by the copyright owner, its agent, or the law.

  • Statement Under Penalty of Perjury: A statement made under penalty of perjury that the information provided in the notification is accurate, and you are authorised to act on behalf of the copyright owner.

  • Signature: An electronic or physical signature of the copyright owner or authorised representative.

Submitting a Valid DMCA Notice Please submit your copyright infringement notification to us via email at


Incomplete or inaccurate notifications may hinder our ability to address the matter promptly. Willis Capital reserves the right to seek clarification or additional information as necessary to process the notification effectively.

Compliance with DMCA Takedown Notices

Willis Capital is dedicated to promptly responding to valid Digital Millennium Copyright Act (DMCA) takedown notices concerning alleged copyright infringements. Upon receipt of a valid takedown notice, we will take swift and appropriate action in accordance with the DMCA guidelines.

Process for Removing or Disabling Access
  • Receipt of Takedown Notice: Upon receiving a valid DMCA takedown notice that complies with the statutory requirements, including but not limited to identifying the copyrighted work and the allegedly infringing material, we will thoroughly review and assess its validity.

  • Content Review: Our team will conduct a prompt review of the identified content alleged to be infringing upon the copyright. This review will include an evaluation of whether the material falls within the scope of the reported copyright infringement.

  • Action Taken: If the content is deemed to be infringing and the takedown notice is valid, we will promptly remove or disable access to the material in question. This action will be taken within the timelines prescribed by the DMCA.

  • Notification to User: If content is removed or access is disabled based on a valid takedown notice, we will notify the user or account holder affected by the takedown, providing information about the action taken and the details of the notice received.


Willis Capital acknowledges that the DMCA establishes a process for addressing alleged copyright infringement and respects the rights of content owners while also ensuring fairness and compliance with the law. We encourage users to engage in lawful practices and respect intellectual property rights in their interactions with our platform.

Protection of User Data
Handling of User Information in DMCA Takedown Processes
  • Confidentiality: Willis Capital is committed to safeguarding the privacy and confidentiality of user information throughout the DMCA takedown process. Any personal data obtained during the handling of a DMCA takedown notice will be treated with utmost confidentiality and used exclusively for the purpose of addressing the alleged copyright infringement.

  • Limited Disclosure: User information provided in response to DMCA notices will only be disclosed to the extent required to assess the validity of the notice, review the alleged infringement, and comply with legal obligations under the DMCA.

  • Data Protection Measures: We employ robust security measures to protect user data obtained during the DMCA takedown process from unauthorised access, misuse, alteration, or disclosure.

Willis Capital places significant importance on protecting user privacy and complying with applicable data protection laws. We strive to balance our commitment to intellectual property rights protection with the obligation to ensure the confidentiality and privacy of our users.


In compliance with applicable privacy laws and regulations, we encourage users submitting DMCA notices to avoid including unnecessary personal information unrelated to the alleged infringement. Willis Capital reserves the right to handle and process user data in line with its Privacy Policy and relevant data protection laws.

Repeat Infringer Policy
Identification of Repeat Infringers
  • Monitoring and Record-Keeping: Willis Capital diligently monitors and keeps records of instances where users are found to have repeatedly violated copyright laws through verified DMCA takedown notices.

  • Identification Process: Upon identifying users with multiple substantiated instances of copyright infringement, Willis Capital designates them as repeat infringers.

Actions Against Repeat Infringers
  • Account Termination: Users identified as repeat infringers are subject to account suspension or termination at the discretion of Willis Capital. This action may result in the immediate cessation of access to our services.

  • Notification of Infringement: Repeat infringers will receive notifications explicitly stating the reason for the account suspension or termination related to copyright infringement violations.

Appeal Process

Users impacted by account suspension or termination have the right to appeal the decision through our established channels within a specified timeframe. Appeals will be reviewed to ensure due process.

Compliance with Legal Obligations

Willis Capital is committed to fulfilling its legal obligations under the Digital Millennium Copyright Act (DMCA) and other relevant intellectual property laws. This commitment extends to taking appropriate actions against repeat infringers to uphold the rights of copyright owners and ensure a compliant and respectful user community.


Willis Capital reserves the right to enforce its Repeat Infringer Policy at its discretion. Appeals regarding account suspension or termination due to repeated copyright infringement must comply with the company's established appeals process.

Disclaimer of Liability
False or Erroneous Notices

Willis Capital operates under the guidelines and provisions of the Digital Millennium Copyright Act (DMCA). While the company takes necessary measures to diligently process DMCA notices and counter notices, it is important to note the following:

  • Third-Party Notices: Willis Capital processes DMCA notices received from copyright holders or their authorised representatives. The company relies on the information provided in these notices and assumes their accuracy.

  • Submission Acknowledgment: The company does not independently verify the accuracy or legitimacy of the information contained within DMCA notices. Consequently, Willis Capital is not liable for damages, losses, or repercussions arising from false, misleading, or erroneous DMCA notices received.

Counter Notification Liability
  • User Responsibility: Users submitting counter notifications are solely responsible for the accuracy of the information provided. Willis Capital assumes no liability for damages resulting from false, inaccurate, or incomplete counter notifications.

  • Submission Acknowledgment: Submitting a counter notification implies acknowledgment that any misrepresentation in the notification may result in legal consequences, including potential liability for damages.

Legal Counsel and Consultation

Willis Capital strongly advises users to seek legal counsel or professional guidance before submitting DMCA notices or counter notifications. Users should ensure the accuracy and legitimacy of the information provided to avoid potential legal repercussions or liability.


This disclaimer of liability is intended to inform users about the limitations of liability on the part of Willis Capital concerning the processing of DMCA notices and counter notifications. Users are encouraged to exercise diligence and seek legal advice when dealing with copyright-related matters.

Policy Review and Updates
Regular Review

Willis Capital acknowledges the dynamic nature of digital copyright laws and commits to conducting periodic reviews of its DMCA policy. These reviews are aimed at ensuring compliance with evolving legal requirements, technological advancements, and industry best practices.

Policy Updates
  • Revisions and Amendments: Any modifications or updates to the DMCA policy will be implemented as deemed necessary by Willis Capital. These changes may arise due to alterations in copyright laws, court rulings, or advancements in digital content regulations.

  • Notification of Changes: In the event of substantial revisions to the DMCA policy, Willis Capital will provide notice of these changes through appropriate channels. Users and stakeholders will be informed of updates through email notifications, website announcements, or other relevant means.

  • Effective Date of Revisions: Revised policies will indicate the effective date of the changes made. Users should regularly review the updated policy to remain informed about any modifications and their effective dates.

User Acknowledgment

By using Willis Capital's services or accessing its platforms, users acknowledge their responsibility to stay informed about the current DMCA policy. Continued use of the services after policy updates implies acceptance of the revised terms and conditions.

Contact for Inquiries

For any queries or concerns regarding the DMCA policy, users are encouraged to contact Willis Capital's designated support team at This contact channel is available for inquiries, clarification on policy updates, or assistance related to copyright matters. Willis Capital reserves the right to revise the DMCA policy at its discretion to ensure compliance with legal requirements and industry standards. Users are advised to review the policy periodically to remain aware of any changes