Content Moderation Policy

1. Purpose

ThirstChat is built on the principle of Real Creators. Real Conversations. We moderate Content and conduct to help keep ThirstChat lawful, safe, and authentic, and to support compliance obligations in the United States, the European Union, and the United Kingdom.

This policy explains:

• what we moderate and why;
• how we detect potential violations;
• what actions we may take;
• how notices, complaints, and appeals work (by reference to your existing policies); and
• how we provide required explanations for decisions (including under the EU Digital Services Act (DSA)).

2. Scope

This policy applies to all activity on ThirstChat, including profiles, posts (if any), messages, call audio/video (whether live or recorded), and any images, videos, or other media shared during a Creator Interaction (“Content”).

We moderate for compliance with:

• the Acceptable Use Policy and Terms of Service; and
• applicable law (including the DSA in the EU and the Online Safety Act 2023 in the UK, where applicable).

3. What We Moderate For

ThirstChat permits lawful adult sexual content and adult conversations between consenting adults; however, we prohibit illegal content and the categories of content and conduct listed in the Acceptable Use Policy (including CSAM, non-consensual intimate imagery, trafficking/exploitation, commercial sexual services or arranging in-person sexual activity for compensation, and any extreme pornography prohibited by law).

We may remove, restrict, or otherwise take action on Content or accounts that we reasonably believe violate our policies or applicable law, including:

3.1 Illegal Content and High-Risk Harm

Including content or conduct involving:

• child sexual exploitation or abuse (CSAM);
• trafficking/exploitation;
• terrorism;
• credible threats of violence;
• intimate image abuse and unlawful sexual content;
• fraud, payment evasion, or other financial crimes; and
• other illegal content identified in the Acceptable Use Policy.

3.2 Platform Integrity and Authenticity

To protect “Real Creators. Real Conversations.” we enforce rules against:

• AI personas, AI chat/voice simulation, or automated messaging used to simulate Creator interaction;
• third-party chat operators or account operation by anyone other than the verified Creator; and
• impersonation, account sharing, and misrepresentation of identity or affiliation.

3.3 Off-Platform Solicitation and Prohibited Transactions

We enforce rules prohibiting:

• attempts to move Users off-platform for continued interaction;
• requests for off-platform payments or alternative payment methods;
• arranging in-person meetings or commercial sexual services; and
• coded language or evasion designed to bypass these restrictions.

We treat attempts to arrange or facilitate commercial sexual services (including in-person meetings for sexual activity in exchange for money or anything of value) as a priority enforcement category.

We may act on coded language or indirect arrangements that reasonably appear intended to facilitate off-platform meetings or commercial sexual services.

4. How Content is Flagged for Review

We use a combination of:

(a) User Reports

Users can report Content or conduct via the mechanisms described in our Complaints Policy and related reporting tools.

(b) Proactive Detection

We may use proactive methods to detect violations and safety risks, including patterns associated with:

• illegal content;
• off-platform solicitation and payment evasion;
• impersonation, account sharing, or third-party operation;
• automated/AI-driven communications; and
• coercion, exploitation, or trafficking indicators.

Pre-Publication Review of Uploaded Content

All uploaded Content will be reviewed before it is published, displayed, made available, or otherwise goes live on ThirstChat. This review may include human review, automated tools, or both, and is intended to confirm compliance with the Terms of Service, Acceptable Use Policy, Content Creator Agreement, this policy, payment partner requirements, and applicable law. ThirstChat will not knowingly permit uploaded Content to go live unless it has first been reviewed and approved through its moderation process.

(c) Notices from Authorities and Other Submissions

We may act on notices from competent authorities and other third parties. In the EU, where applicable, we process notices consistent with the DSA notice mechanisms and may prioritize certain qualified submissions (including those from trusted flaggers, where applicable).

5. Tools Used in Moderation

Moderation may include human review, automated tools, or both.

Automated tools may be used to help detect and triage potential violations (for example, identifying suspected illegal content, spam, scam patterns, or off-platform solicitation). Automated tools may also help identify authenticity risks (such as unusual account-operation patterns).

Automated tools assist review but do not guarantee accuracy. Where required by law, we will disclose when automated tools played a material role in a restriction decision and provide a way to request human review through the Appeals Policy.

5.1 Real-Time Monitoring of Live Content

Because ThirstChat includes live audio and live video Creator Interactions, live content and live communications may be monitored in real time or near real time for safety, legal compliance, payment partner compliance, fraud prevention, and enforcement of the Terms of Service, Acceptable Use Policy, Content Creator Agreement, and this policy.

Real-time monitoring may include automated tools, human review, metadata analysis, user reports, transaction review, keyword or pattern detection, and review of screenshots, recordings, transcripts, logs, or other session information where available and permitted by law. Automated tools may help identify and triage suspected violations, but they do not guarantee that every violation will be detected.

We may interrupt, suspend, or terminate any live Creator Interaction, restrict access to live features, preserve records, require additional verification, or take other enforcement action if we reasonably believe the interaction involves or may involve illegal content, minors, nonconsensual content, trafficking or exploitation, prostitution or solicitation, commercial sexual services, off-platform solicitation, payment evasion, impersonation, coercion, fraud, or any other violation of our policies or applicable law.

Creators and Fans must not attempt to evade, disable, interfere with, or mislead our monitoring, reporting, safety, or enforcement systems. Users should immediately report live interactions that appear to involve minors, nonconsensual conduct, trafficking, exploitation, prostitution or solicitation, coercion, blackmail, threats, fraud, or other illegal or prohibited activity.

Where we take action on live content or a live Creator Interaction, we will provide notice, reasons, complaint options, or appeal rights where required by applicable law and our policies, except where notice would be unlawful, would risk harm, would compromise an investigation, or would be technically infeasible.

6. Decision-Making Principles

When evaluating Content or conduct, we may consider:

• the type and severity of the suspected violation;
• context (including whether it appears coercive, exploitative, or fraudulent);
• the likelihood of harm;
• whether the behavior appears intentional or part of an evasion pattern; and
• whether the issue can be addressed through a less restrictive measure.

We may act without prior notice where necessary to address illegal content, prevent harm, preserve evidence, or comply with legal obligations.

We may also preserve records and cooperate with law enforcement, regulators, and, where relevant, our payment processors and banking partners to investigate suspected fraud, illegal content, or policy violations, consistent with applicable law.

7. Actions We May Take

Depending on the circumstances, we may:

• remove or disable access to Content;
• restrict visibility or sharing of Content;
• restrict product features (e.g., messaging, calls, uploads);
• interrupt, suspend, or terminate any live Creator Interaction (including a phone call or 1-on-1 video chat) and restrict access to live features where we reasonably believe it violates our policies or applicable law;
• issue warnings or require acknowledgments;
• require additional information or re-verification (including identity and/or age verification) as a condition of continued access or use;
• temporarily suspend accounts;
• permanently terminate accounts;
• take steps to prevent ban evasion or coordinated abuse;
• where permitted by law and our agreements, hold, delay, suspend, withhold, reverse, or adjust payouts or other funds where we reasonably suspect fraud, payment evasion, coercion/exploitation, policy evasion, unauthorized use, or chargeback/dispute abuse;
• restrict or terminate accounts associated with excessive disputes/chargebacks or suspected unauthorized use.

For serious violations (including suspected CSAM, trafficking, credible threats, or other imminent harm), we may take immediate action and may make reports or referrals where required or appropriate under applicable law.

8. Notice, Complaints, and Appeals

8.1 Complaints and User Reports

How to submit a complaint or report Content is described in our Complaints Policy.

8.2 Appeals

How to appeal Content removals or account restrictions is described in our Appeals Policy.

8.3 DMCA Notices

Copyright takedown notices and counter-notices are handled under our DMCA Policy.

8.4 TAKE IT DOWN Act Compliance

Reports and requests covered by our TAKE IT DOWN Act Compliance Policy are handled under that policy.

If multiple policies could apply to the same report, we may route and process the report under the policy that best fits the request and legal requirements.

9. Statements of Reasons and User Notification

Where required (including under the EU DSA for in-scope decisions), we will provide a statement of reasons for certain Content moderation or account restriction decisions. This may include:

• the policy or legal basis for the action;
• the type of restriction applied and its scope;
• whether automated tools were used in a material way; and
• available complaint and appeal options.

10. Transparency

We may publish periodic transparency reporting regarding Content moderation activities, consistent with applicable legal requirements (including DSA transparency reporting obligations where applicable).

11. Contact

Questions about this Content Moderation Policy can be sent to: support@thirstchat.com.