Content Moderation Policy

By using PlayHouse you agree to this policy. Please read it carefully.

Contents

1. Introduction
2. Interpretation
3. Why and when we moderate
4. What we moderate
5. How we moderate: our tools
6. How we moderate: reports
7. How we moderate: human review
8. Live streams and video calls
9. What we may do
10. Statements of reasons and outcome notices
11. Serious and repeated violations
12. Illegal Content and reporting to authorities
13. Appealing a decision
14. Our principles

1. Introduction

This Content Moderation Policy explains when, why and how PlayHouse moderates Content and conduct, and what happens when Content or conduct breaks our Terms of Service. PlayHouse is owned and operated by Vallara, Inc., a Delaware corporation. If you are a User, this policy forms part of your agreement with us. Key points:

• What is and isn't allowed on PlayHouse is set out in our Terms of Service and Acceptable Use Policy.
• We use automated tools and human review. Automated tools check uploads and text; trained people review what is flagged or reported.
• Every moderation decision comes with a statement of reasons that explains what we decided, why, and how to appeal.
• You can appeal under our Appeals Policy.

2. Interpretation

Words defined in our Terms of Service (such as User, Creator, Fan, Agency and Content) have the same meaning in this policy.

3. Why and when we moderate

3.1 PlayHouse lets Creators earn from their Content and connect with their Fans. To protect our community and to comply with the law, we moderate Content and conduct to check that they comply with our Terms of Service, including our Acceptable Use Policy.

3.2 We moderate when Content is uploaded, when our automated tools flag something, when someone reports something to us, and at any other time we choose. We are not obliged to review all Content, and people do not review all Content before it is published.

4. What we moderate

4.1 We may review, restrict or remove any Content shared on PlayHouse, including photos, videos, audio, text, profiles, stories, comments, direct messages, live streams and video calls, and we may act on any conduct on PlayHouse.

4.2 Our Acceptable Use Policy lists what is not allowed. The most common reasons we act include Content that:

• shows, involves or suggests anyone under 18 in a sexual context, or anyone who appears to be under 18, including in role-play;
• shows anyone who has not consented to it, or shares intimate images of someone without their consent;
• shows another person in explicit Content who is neither a verified PlayHouse Creator nor covered by a completed co-performer release form;
• impersonates someone else;
• is illegal where it was made or where it is shared;
• shows extreme violence, gore, weapons, illegal drugs or self-harm;
• promotes hate, harassment or threats against anyone;
• arranges meeting in person or offers sexual services; or
• takes a conversation or a payment off PlayHouse, for example by sharing contact or payment details.

5. How we moderate: our tools

5.1 Checks at upload. Photos and videos uploaded to PlayHouse, including in posts, stories, messages, profiles, the vault and custom orders, are checked when they are uploaded and before they are published, using:

1. Hash lists. A hash is a digital fingerprint of an image or video. We compare each upload against hash lists of known harmful material: the StopNCII.org hash bank of non-consensual intimate images, and the hash list of NCMEC's Take It Down service for intimate images of people who were under 18 when the image was taken.
2. Microsoft PhotoDNA, which detects known child sexual abuse material (CSAM).
3. Automated image and video classification tools, which estimate whether an image or video shows nudity, the apparent age of the people shown, violence, gore, weapons, recreational drugs, self-harm or offensive symbols, or may be a deepfake. The deepfake check only flags Content for a person to review; it never removes anything by itself.

5.2 When a check flags an upload, we may hold it, mark it as sensitive or send it to our team for review. If an upload matches a CSAM hash list or PhotoDNA, it is held and our specialist child-safety team is alerted (see section 12).

5.3 Re-checks. When the hash lists we use are updated, we check Content already on PlayHouse against the new entries and act on any match.

5.4 Text rules. Automated text rules check direct messages, mass messages, post and story captions, and profile display names and bios for prohibited terms and for contact details, payment handles, cryptocurrency addresses, off-platform messaging handles and attempts to move a conversation or payment off PlayHouse. A matching message may be held, and other matches are sent to our team for review.

5.5 Files in messages. Documents sent in messages are checked to confirm they are a permitted file type, and refused if they are not.

6. How we moderate: reports

6.1 Signed-in Users can report Content using the Report action on posts (wherever they appear), profiles and accounts, stories, comments, individual messages and whole conversations, live streams and video calls.

6.2 Anyone, signed in or not, can report:

• illegal or harmful Content, through our contact form by choosing Report illegal or harmful content;
• an intimate image of them shared without their consent, through our intimate image removal form; and
• copyright infringement, through our DMCA request forms.

6.3 Every report is reviewed by our team. Reports about the most serious harms, such as Content that may involve a child or intimate images shared without consent, are reviewed first. While a post is under review, we take it out of discovery surfaces such as Explore.

6.4 When we receive a valid request to remove an intimate image shared without consent, we remove it within 48 hours and make reasonable efforts to find and remove identical copies on PlayHouse. Read more in Non-Consensual Intimate Imagery and Consent.

6.5 Our Complaints Policy explains every reporting route in full.

7. How we moderate: human review

7.1 Trained members of our team review Content that our tools or our users flag, and decide what action to take.

7.2 Suspected child sexual abuse material and suspected non-consensual intimate imagery are handled only by a restricted, specially trained team.

7.3 Access to sensitive material is restricted and recorded, and we take steps to protect the well-being of the people who review it.

7.4 Serious decisions, such as banning an account or forfeiting earnings, receive senior review.

8. Live streams and video calls

8.1 We moderate live streams and video calls in real time through reports from viewers and participants and through action by our team, who can stop a stream or end a call. Live streams and video calls are not recorded.

8.2 Only Fans who have passed age assurance can join live streams. A stream's cover image is the Creator's profile photo, which is checked at upload.

9. What we may do

9.1 If Content or conduct breaks our Terms of Service, we may do one or more of the following, depending on how serious it is:

• remove the Content;
• restrict the Content: it stays visible to the Creator's subscribers but is marked as sensitive and taken out of discovery;
• warn the User;
• stop a live stream or end a video call;
• suspend or freeze the account, so that the User can't sign in or use some features;
• ban the User from PlayHouse;
• hold earnings while we investigate, and, where our Terms of Service allow, forfeit earnings connected with a serious violation; and
• refund Fans' purchases to their wallet.

9.2 If we have strong evidence that an account has shared CSAM, the account is frozen immediately: the User can't sign in and earnings are held.

10. Statements of reasons and outcome notices

10.1 If we act on your Content or account, we send you a statement of reasons by email. It tells you:

• what we decided, which Content or account it affects and, for a restriction, how long it lasts;
• the facts and circumstances we relied on, including whether we acted on a report or on our own initiative;
• whether automated tools were used to detect the Content or to make the decision;
• the rule in our Terms of Service, or the law, that the decision is based on, and why; and
• how to appeal, and any other options you have, such as out-of-court dispute settlement in the EU.

10.2 If you report Content, we confirm that we've received your report and tell you the outcome, including whether we took action and, if we didn't, how you can ask us to look again.

10.3 We may limit what we tell you where the law requires it, or where telling you could harm an investigation or put someone at risk, for example in a child-safety case.

11. Serious and repeated violations

11.1 If a User commits a serious violation, or repeatedly breaks our Terms of Service, we may suspend or ban their account without a prior warning and may prevent them from opening new accounts.

11.2 We keep a record of valid copyright notices against each account, and we terminate the accounts of repeat infringers in appropriate circumstances, as described in our DMCA and Copyright Policy.

12. Illegal Content and reporting to authorities

12.1 We remove illegal Content, and a User who posts it may be banned permanently. We may hold or forfeit earnings connected with illegal Content where our Terms of Service allow.

12.2 We report apparent child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC) through its CyberTipline, as US law (18 U.S.C. §2258A) requires. We preserve the reported Content and related information in secure, tamper-proof storage for at least as long as the law requires. Read more in Combating Child Sexual Abuse Material.

12.3 If we become aware of information suggesting that someone's life or safety is at risk, including a criminal offense involving such a threat, we promptly inform the relevant law-enforcement or judicial authorities and give them the information we have. We also share information with law enforcement where the law requires it. Read more in Assisting Law Enforcement, and see our Privacy Policy.

13. Appealing a decision

If you think we got a decision wrong, you can appeal within six months. For a decision about your Content, use Appeal a moderation decision (you need to be signed in). For a decision about your account, use our appeal form. Every appeal is decided by someone who was not involved in the original decision. Decisions about child sexual abuse material and non-consensual intimate imagery have their own review route. Our Appeals Policy explains how appeals work.

14. Our principles

We aim to moderate consistently, carefully and without discrimination, in keeping with the law and with the internationally recognized human rights of our Users, as set out in the United Nations Guiding Principles on Business and Human Rights, including the rights to freedom of expression and to privacy.