CONTENT MODERATION POLICY

Effective Date: June 1, 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

• U.S. federal & state laws (incl. 18 U.S.C. § 2257, COPPA)
• Trafficking Victims Protection Act (TVPA)
• EARN IT & FOSTA-SESTA requirements
• Visa ADCR, Mastercard BRAM
• GDPR (EEA users)

4. Content Categories Subject to Moderation

• Public live streams
• Private live streams (if recorded or accessible by ClamCams)
• Profile pictures & usernames
• Promotional content (banners, avatars, teaser videos)
• Pre-recorded content (clips, replays, previews)
• ID verification media & documents

5. Prohibited Content

• Any content involving or simulating minors (real or fictional)
• Bestiality, incest, non-consensual acts, rape (real or simulated)
• Sex trafficking, exploitation, or coercion
• Physical violence, mutilation, torture
• Drug use or depiction of illegal substances
• Material violating U.S. or local law, or card-brand requirements
• Pre-recorded videos presented as live without disclaimer

6. Moderation Process

6.1 Pre-Publication Review

• Mandatory moderation of all pre-recorded content.
• Hybrid system: automated AI + human moderation.
• Checks for prohibited visuals, metadata inconsistencies, rule violations.

6.2 Live Content Supervision

• Real-time ML models detect risk indicators during broadcasts.
• Alerts escalate to compliance team for human intervention.
• Flagged streams may be interrupted and audited.

6.3 Document & Identity Verification

• All models complete KYC:
• Government-issued ID
• Live selfie with liveness detection
• Age validation (18+)
• Forgery or impersonation = immediate suspension.

7. Enforcement and Sanctions

• Temporary or permanent suspension
• Forfeiture of earnings or bonuses
• Reporting to law-enforcement or regulators
• Blacklisting from future access

8. Appeals and Redress

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

• Reference to the flagged content or session
• Statement of facts
• Supporting documents or media

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.