Content Moderation Policy

1. Our Commitment

MyShrine, operated by Aquila Global Ltd, operates a zero-tolerance policy on illegal content. We are committed to providing a safe platform for adult content creators and fans, while strictly prohibiting any content that is illegal, harmful, or exploitative.

This policy is compliant with the UK Online Safety Act 2023, the EU Digital Services Act (DSA), and all applicable laws in the jurisdictions in which the Platform operates.

2. Permitted Content

The following categories of content are permitted on the Platform, subject to compliance with all other provisions of this policy and our Terms & Conditions:

• Legal adult content between consenting adults who are verifiably 18 years of age or older;
• Content produced in compliance with 18 U.S.C. § 2257 (where applicable) and equivalent legislation in the relevant jurisdiction;
• Fetish, BDSM, and lifestyle content between consenting adults;
• Custom content produced by a Creator in accordance with a brief agreed between the Creator and a Fan;
• Non-explicit creative, artistic, or educational content.

3. Prohibited Content — Zero Tolerance

The following content is strictly prohibited and will result in immediate removal, account suspension, and, where required by law, referral to the relevant authorities:

3.1 Child Sexual Abuse Material (CSAM)

Any content that depicts, references, or simulates persons under 18 years of age in a sexual context is absolutely prohibited. Such content will be:

• Immediately removed from the Platform;
• Reported to the National Crime Agency (NCA) via the CSEA Industry Reporting Portal, as required by the UK Online Safety Act 2023;
• Reported to the Internet Watch Foundation (IWF) (UK);
• Reported to relevant law enforcement authorities.

3.2 Non-Consensual Content

Any content that constitutes non-consensual intimate imagery, is presented as non-consensual, or that depicts sexual activity without the evident consent of all participants is strictly prohibited. This includes AI-generated or digitally altered intimate imagery (deepfakes) depicting any person without their consent, in compliance with the TAKE IT DOWN Act (18 U.S.C. § 1309).

Individuals depicted in non-consensual intimate imagery (including AI-generated/deepfake content) may submit a removal request via our dedicated TAKE IT DOWN Act Removal Request page. Valid requests are actioned within 48 hours, and all known identical copies will also be removed.

3.3 Sex Trafficking & Commercial Sexual Exploitation

In accordance with FOSTA-SESTA (18 U.S.C. §§ 2421A, 1591), the following are strictly prohibited on the Platform:

• Content that promotes, facilitates, or constitutes sex trafficking;
• Content that solicits or advertises prostitution or commercial sexual services;
• Content that facilitates the commercial sexual exploitation of any person;
• Any content, communication, or transaction designed to circumvent the above prohibitions.

Violations will result in immediate account termination, content removal, and referral to the NCA, FBI, and relevant law enforcement agencies as required by law.

3.4 Additional Prohibited Categories

• Content depicting real violence, gore, or serious physical harm;
• Rape or simulated rape, or any content presented as non-consensual;
• Death or simulated death;
• Defecation or scat;
• Incest, including role-play between family or step-family members;
• Bestiality;
• Content involving or promoting the use of illegal drugs or controlled substances;
• Doxxing — sharing private personal information of third parties without their consent;
• Defamatory, harassing, or threatening content directed at any individual;
• Content that infringes any third-party intellectual property rights;
• Any content that violates applicable law in any jurisdiction in which the Platform operates.

4. Moderation Process

All photos, videos, and audio submitted for sale in a Creator's store pass through the following moderation workflow. Other images and videos (profile and banner images, wishlist images, custom deliveries, and message media) pass through the same automated checks in steps 2 and 3 and are blocked if flagged. Live streams must comply with this policy: still frames from each broadcaster's camera are captured throughout the broadcast and pass through the same automated checks (streams showing suspected child sexual abuse material are ended automatically; other flags alert our moderation team), streams may be monitored in real time by our moderation team, can be reported by any viewer via the Report button on the stream or our report form, and may be ended by us at any time.

1. Upload: Creator uploads content. It is not visible to any other user until the checks below are complete.
2. Automated CSAM Hash Matching: Every image and video is immediately checked against the Project Arachnid Shield database (operated by the Canadian Centre for Child Protection), which contains cryptographic fingerprints of known CSAM. Any match results in instant rejection and escalation — no human review required for this step.
3. Automated AI Moderation: Content is simultaneously scanned by Sightengine AI, which detects apparent minors in sexual contexts, extreme violence, gore, and hate speech. Flagged content is auto-rejected and admin-alerted.
4. Human Moderation Review: Files the scanners cannot check, custom deliveries, each creator's first five uploads and a random sample of other uploads wait for a moderator, usually within 24 hours. Other files that pass the automated checks are published automatically.
5. Approved Content: Content that complies with this policy is approved and published to the Creator's storefront.
6. Rejected Content: Content that violates this policy is rejected. The Creator is notified with the reason for rejection. The content is permanently removed and cannot be re-submitted.
7. Illegal Content: Content that appears to be illegal is immediately escalated, the account is suspended, and the content is reported to the relevant authorities as required by law.

5. Takedown Service Level Agreement (SLA)

• Reported content reviewed: Within 72 hours of receipt of a valid report.
• Verified illegal content removed: Within 1 hour of confirmation of illegality.
• CSAM: Immediate removal upon identification, with simultaneous reporting to the NCA, IWF, and Cybertip.ca.
• TAKE IT DOWN Act requests: Content identified in a valid removal request (NCII/deepfake) removed within 48 hours, including all known identical copies.

These timescales are consistent with our obligations under the UK Online Safety Act 2023, the EU Digital Services Act, and the TAKE IT DOWN Act (18 U.S.C. § 1309).

6. Creator Appeals

Creators who believe that content has been incorrectly rejected may appeal the moderation decision by emailing support@myshrine.io with the subject line "Moderation Appeal" within 14 days of receiving the rejection notification.

Appeals are reviewed by a senior member of the moderation team within 72 hours. The decision of the senior moderator is final.

Appeals will not be considered for content involving CSAM or other categories of content that are illegal under applicable law.

7. Reporting Content

If you encounter content on the Platform that you believe violates this policy, you can report it using the report function available on each content page, or by emailing support@myshrine.io with the subject line "Content Report".

For child safety content specifically, in addition to reporting to us, please also report directly to:

• National Crime Agency (NCA) — CEOP: ceop.police.uk
• Internet Watch Foundation (IWF): iwf.org.uk
• Canadian Centre for Child Protection (Cybertip.ca): cybertip.ca
• Your local law enforcement authority

For removal of non-consensual intimate imagery (including AI-generated/deepfake content), use our dedicated TAKE IT DOWN Act Removal Request form.

8. Data Retention for Reported Content

In accordance with the REPORT Act (S.474, 118th Congress) and our obligations under UK and US law, we retain the following data for a minimum of one (1) year from the date of a report or removal:

• Cryptographic hash values of removed content (for re-upload detection);
• Report metadata including report type, date, case reference, and reporter contact information;
• Account information of the uploader at the time of removal;
• Moderation decisions and timestamps.

This retention ensures we can respond to law enforcement requests, prevent re-upload of removed material, and comply with our reporting obligations to the NCA, IWF, and Cybertip.ca.