Snapchat was designated a very large online platform under the Digital Services Act on 25 April 2023, in the European Commission first wave of designations. Those obligations apply to account restrictions, not only to individual pieces of content.
Article 17 requires a clear and specific statement of reasons for a restriction, including the facts relied on and the ground invoked. Article 20 requires an internal complaint-handling system that is free, accessible, and does not rest on automated means alone. Article 21 opens a route to a certified out-of-court dispute settlement body once the internal complaint is exhausted. Snap points users towards that route without naming a body, inviting them to "contact one of the out-of-court dispute settlement bodies that has been certified in accordance with Article 21.3". Worth noting: the Appeals Centre Europe, which handles disputes for Facebook, Instagram, Pinterest, Threads, TikTok and YouTube, does not currently cover Snapchat. The certified bodies are listed by the European Commission:
out-of-court dispute settlement under the DSA.
Article 15 of the GDPR gives a separate right of access to the personal data Snap holds about the account. It can be exercised whatever the outcome of the appeal, and what it returns often documents the file better than the notice did.
One structural point sets Snapchat apart. Snap Group Limited, the company that contracts with users outside the United States, is established in the United Kingdom and therefore outside the European Union. Under Article 13 of the Digital Services Act it has designated Snap B.V., in Amsterdam, as its legal representative in the Union, mandated to receive communications. Formal correspondence concerning an EU account is addressed there.
AccountRights is not a law firm. Whether any of these grounds applies to a given account is for an independent lawyer to determine.