COMPLAINTS POLICY We are NEXORAN LTD, having been duly registered in UK and having Company’s number 15998670 and address: City Road, 124, London, United Kingdom, EC1V 2NX Key objectives The main objectives of our complaints policy are: • Ensure that anyone wishing to make a complaint, of any nature, about any content on our site is able to make that complaint easily; • Ensure that it is simple to report, and completely clear how to report, content that is potentially illegal, abusive, non-consensual, or otherwise inappropriate; • Ensure that every complaint is dealt with quickly and professionally, with the maximum assistance given to every person who writes to us; • Ensure every complaint is resolved, and any required action taken, within seven days. Key processes Our key processes in ensuring we meet our key policy objectives are as follows: • We provide several easy ways for anyone to make complaints to us: o If they have a registered account with us then they can email us directly from their member account; o Anyone can email us using our public email address at [email protected], which is shown on the Contact Us page on our site; o Anyone can complete the contact form on the Contact Us page (which has a dropdown menu where Complaint or can be selected) or click on the Send Email link on that page. • Our customer service team operates on a 24/7 basis, and all complaints are immediately acknowledged; • Depending on the nature of the complaint it is dealt with by the customer service team and/or it is escalated to a more senior team member, including members of the compliance team and management team (the Head of Compliance is a member of the management team); • Every complaint relating to potentially illegal, abusive, non-consensual, or otherwise inappropriate content is sent immediately to both the compliance team and the management team; • Every complaint is signed off as resolved only after at least two different people have reviewed the case, one of whom will be more senior than the other; • Every complaint is recorded as a ticket on our customer management system so it can be tracked throughout the resolution process. This ensures that nothing gets missed, all correspondence is kept together, and the issue is resolved within the timescale agreed; • In the case of illegal content, or content that could potentially be illegal, the content will be removed immediately; • If a user wants their content removed then there is no question about whether that should be done – we give every single content provider the absolute right to have their content removed from our site; Nobody can upload content to our site that contains images or video of any person other than themselves, and they can only upload content of themselves to our site after they have been through our onboarding process (see our Onboarding Policy), meaning that they will have been identified and age-verified and they will have provided their full written consent. All uploaded content is fully moderated before it goes live on the site; • Any content that is reported to us that does not meet our stringent criteria, even if legal, is removed immediately and without question, and the uploader of the content is reviewed and dealt with as appropriate – which would typically mean being banned from our site permanently. Every case is dealt with separately and on its own merits; • If there was ever a case that couldn’t be resolved internally then it would be referred to a neutral arbitration organisation at our own expense (this has never been necessary). We reduce the likelihood of anyone needing to request for their own content to be removed by operating an account suspension and deletion process, based on the activity on the account. This process is in part guided by the requirement of the GDPR data protection requirements, which require that data shouldn’t be kept any longer than is reasonably necessary: • After three months of inactivity a member account is suspended, which means that profile is removed from our site and her content cannot be viewed by anyone. • If within the next three months the member becomes active again then its account is reactivated automatically. However, if it remains inactive for the next three months being inactive for a total of 6 months then her account is deactivated. Once the account has been deactivated then a member needs to contact our customer service team to reactivate it and you will need to go through the entire onboarding process again. • If the account remains inactive for 12 months in total then the account, and all the related content, is deleted. At this point the account cannot be reactivated and all content is completely removed and not capable of being recovered. If the member comes back to us after those 12 months then it comes back to us as a new member and of course is required to fulfill the then current onboarding requirements.