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CONTENT MODERATION POLICY

Effective Date: December 9, 2025

1. Purpose

This Content Moderation Policy (“Policy”) defines the mechanisms and standards by which ClamCams ensures that all content complies with applicable laws, card-brand rules (Visa & Mastercard), and ClamCams’ internal codes of ethics. The Policy is binding on all users, including models, studios, content managers, and third-party providers.

2. Scope of Application

This Policy applies to all content—live or pre-recorded—streamed, uploaded, or distributed through ClamCams, as well as all related metadata, promotional materials, thumbnails, usernames, profile images, and verification documents.

3. Legal Framework and Industry Standards

4. Content Categories Subject to Moderation

5. Prohibited Content

6. Moderation Process

6.1 Pre-Publication Review

Mandatory moderation of all pre-recorded content.

Hybrid system combining automated AI tools with human moderation.

Checks for prohibited visuals, metadata inconsistencies, and rule violations.

6.2 Live Content Supervision

Real-time machine-learning models detect risk indicators during broadcasts.

Alerts are escalated to the compliance team for human intervention.

Flagged streams may be interrupted and audited.

6.3 Document & Identity Verification

All models must complete KYC, including:

Forgery or impersonation results in immediate suspension.

6.4 Participant Consent Controls (All Participants / Co-Performers)

ClamCams requires affirmative, documented consent from all participants appearing in any live stream or uploaded content.

Creator Attestation (Required): During onboarding and prior to streaming/uploading, creators must attest that: (i) all participants are 18 years of age or older; and (ii) all participants have provided affirmative consent to be recorded and distributed on the platform.

Co-Performer / Third-Party Requirement: Creators may not include any additional participant unless that individual meets ClamCams’ verification requirements or the creator can provide a valid co-performer consent record upon request. If consent/verification cannot be produced, the content may be restricted or removed and enforcement actions may apply.

Monitoring & Enforcement: ClamCams uses automated AI monitoring, user reports, risk flags, and human review to identify potential non-consensual content or unverified participants. AI-generated alerts are escalated to designated supervisors/compliance staff for timely human intervention. Where non-consensual or unverified participation is suspected, ClamCams may temporarily restrict access to the content while requesting documentation and conducting a compliance review.

Recordkeeping: Consent-related records and verification artifacts are stored securely with role-based access controls and audit logging, and are retained in accordance with applicable law and card-brand requirements.

6.5 Third-Party Identification Controls (Identification of 3rd Parties in Media)

ClamCams implements technical and operational controls to identify and prevent unverified third parties from appearing in live streams or uploaded content. Any additional participant must comply with the requirements in Section 6.4.

Suspected third-party appearances are detected through automated AI monitoring, user reports, risk flags, and human review; AI-generated alerts are escalated to designated supervisors/compliance staff.

Camera Partner Permissions (Verified-Only Appearance): ClamCams enforces a verified-only co-performer workflow. A creator may only add another person to appear on camera if that person has an existing verified ClamCams model account. The creator sends an invitation and the co-performer must accept it before appearing, generating an auditable permission record (status and timestamp).

When suspected violations occur, ClamCams may temporarily restrict access to content or interrupt a live stream while requesting documentation and conducting a compliance review. Confirmed violations may result in content removal and enforcement actions.

6.6 Consumer Age Verification Controls (U.S. State AVS Laws)

ClamCams restricts access to adult content and platform features to users who are 18 years or older, and implements additional jurisdiction-based age verification where required by U.S. state law.

Jurisdiction Detection: ClamCams uses geolocation signals (e.g., IP-based location and related indicators) to determine whether a user appears to be accessing the site from a jurisdiction with mandatory age-verification requirements.

Step-Up Age Verification: When a user is detected in a jurisdiction requiring age verification, ClamCams requires that user to complete age verification prior to accessing adult content and/or restricted features.

Verification Provider: Age verification is performed through Yoti (or an equivalent third-party provider) using approved verification methods. The provider’s result is used to grant or deny access.

Data Minimization & Recordkeeping: ClamCams retains only the minimum necessary verification outcome (for example, pass/fail, timestamp, and a reference token) and does not store unnecessary sensitive identity information. Records are maintained securely with role-based access controls and audit logging.

Failure to Verify: If age verification cannot be completed or is unsuccessful, access is denied for jurisdictions requiring AVS.

7. Enforcement and Sanctions

8. Appeals and Redress

Models may appeal moderation decisions within 72 hours via compliance@clamcams.com, including:

9. Record-Keeping

All moderation actions (AI flags & human decisions) are logged and retained for at least two (2) years.

10. Policy Updates

This Policy is reviewed quarterly or when laws/card-brand rules change. The latest version is always available at clamcams.com/content-policy.

ClamCams is committed to ethical, lawful, and transparent operation. Moderation is not censorship — it is protection.

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