Non-Consensual Content (NCC) Policy

Version 1.0 – Effective Date: October 15, 2025

1. Purpose

This policy aims to prevent, detect, and eliminate any content depicting sexual, erotic, or intimate acts that has been uploaded, distributed, or stored on the Platform without the explicit, verifiable, and documented consent of every identifiable individual appearing in such content.

This policy is a core compliance requirement designed to:

• Protect the dignity, privacy, and sexual autonomy of individuals.
• Comply with international regulatory frameworks (DSA, FOSTA-SESTA, 18 U.S.C. §2257, StopNCII.org).
• Mitigate regulatory, reputational, financial, and operational risks identified in the Corporate Risk Map.
• Support a zero-tolerance approach toward the dissemination of non-consensual content.

Seacrets adopts a zero-tolerance approach toward the dissemination of non-consensual content by implementing technical, contractual, and human controls across all stages of content management.

2. Scope

Affected Parties

• Content Creators: Upload, stream, or monetize audiovisual or textual material.
• Fans/Consumers: Access, view, purchase, or share content.
• Employees and Contractors: Operational, engineering, support, or legal roles.
• Authorized Third Parties: Moderators, processors, integrated platforms, technology providers.

Covered Activities

• Uploading
• Live streaming
• Automated or manual processing
• Active or backup storage
• Replication or internal distribution
• Permanent deletion or legally required preservation

3. Key Definitions

4. Guiding Principles

4.1 Legality and Due Diligence

• Compliance with 18 U.S.C. §2257 and international privacy and CSAM laws.
• Alignment with GDPR, LGPD, DMA, and payment network policies.
• Pre-publication verification of age, identity, and consent for all participants.

4.2 Informed, Specific, and Revocable Consent

• Consent must be informed, specific, verifiable, and revocable at any time.
• Revocation triggers immediate removal of all associated content.

4.3 Proportionality and Minimum Data Exposure

• Data used strictly for verification and compliance.
• Retention limited to legal requirements, including §2257 records.
• Encrypted, segmented, and fully traceable access.

4.4 Transparency and Traceable Evidence

• Full documentation of detection, review, removal, and reporting actions.
• Evidence made available to law enforcement, payment partners, and affected individuals.

5. Mandatory Rules and Controls

6. Reporting and Response Procedure

6.1 Reporting Channels (24/7)

• “Report” button on all content
• Email: [email protected]

6.2 Initial Classification (≤ 24 hours)

• CSAM
• NCC
• Other violations

6.3 Immediate Actions

CSAM

• Immediate blocking and removal
• Account suspension and fund freeze
• Mandatory reporting to NCMEC and LEA
• Device/IP blocking and evidence preservation

NCC

• Internal investigation within 48 hours
• Preventive blocking when required
• Evidence preservation

6.4 Notifications and Transparency

Affected users receive confirmations, updates, and outcomes. Payment partners notified if required.

6.5 Appeal Procedure

• Appeal within 7 days
• Submit new evidence or identification
• Compliance Officer issues final resolution

6.6 Appeals Policy for Content Removal

• Submission via email with proof of consent or identity
• Reviewed within 2 business days
• Option for neutral third-party review

7. Roles and Responsibilities (RACI)

8. Training and Awareness

• Mandatory onboarding training
• Annual updates on NCC, CSAM, AI review
• Quarterly simulations
• 95% moderators must pass annual technical exam

9. Measurement and KPIs

10. Review and Continuous Improvement

The NCC Policy is reviewed annually or earlier due to regulatory changes or increased risks. Updates must be approved by the Board and added to the Version History.

11. Version History