CONTENT MODERATION POLICY

We are NEXORAN LTD, having been duly registered in UK and having Company’s number 15998670 and address: 124 City Road, London, United Kingdom, EC1V 2NX


DISCLAIMER
GROOMBO's Services are provided "as is" and we do not make, and cannot make, any representations about the content or features of our Services or Member’s content.
We provide our services on an "As is" and "As available" basis and to the extent permitted by applicable law, grant no warranties of any kind, whether express, implied, statutory or otherwise with respect to our services (including all content contained therein), including, without limitation, any implied warranties of satisfactory quality, merchantability, fitness for a particular purpose or non-infringement. We do not represent or warrant that (a) our services will be uninterrupted, secure, or error free, (b) any defects or errors in our services will be discovered or corrected, or (c) that any content or information you obtain on or through our services will be accurate, complete, current or appropriate for your purposes. Furthermore, we do not make guarantees as to the number of active users at any time; users' ability or desire to communicate with or meet you, or the ultimate compatibility with or conduct by users you meet through the services.
We assume no responsibility for any content that you or another user or third party posts, sends, receives, or acts on through our services, nor does GROOMBO assume any responsibility for the identity, intentions, legitimacy, or veracity of any users with whom you may communicate with through GROOMBO. Any material downloaded or otherwise obtained through the use of our services is accessed at your own discretion and risk. GROOMBO is not responsible for any damage to your computer hardware, computer software, or other equipment or technology including, but without limitation, damage from any security breach or from any virus, bugs, tampering, hacking, fraud, error, omission, interruption, defect, delay in operation or transmission, computer line or network failure, or any other technical or other disruption or malfunction.

Key objectives
Our key objectives in monitoring the content that appears on the site are:

•	Ensure that every member on photo is the same person as the person that has been identified and verified as being over 18 during the onboarding process;

Ensure that every still photograph and short preview videos forming part of member’s profiles:
•	Contains no illegal content (including incest, bestiality, rape);
•	Contains no signs of child exploitation or child abuse, or indeed any involvement in any way of anyone who might be a minor;
•	Has no evidence of the member being subject to any form of coercion or of anything that appears to be non-consensual (including non-consensual mutilation of a person or body part);
•	Has no content that contravenes our Terms of Use;
•	Contains no content that is designed to imply that any illegal content or other inappropriate content might be available
•	Contains no computer-generated or computer-modified content that includes a realistic version of any identifiable person other than the registered member (including but not limited to content that could be described as “deepfake”)
•	Ensure that no adult content (video or pictures) is available to non-members

Monitoring controls and processes
We have a dedicated moderation team whose sole role is to monitor the content appearing on our site, both static content, including text and pictures. This team provides live monitoring on a 24/7 basis.
The moderation team is augmented by members of the management team, who have to review and approval responsibilities at various stages of the moderation process.

The main controls and processes in place to monitor all content appearing on the site are:
•	Our standard moderation process for reviewing pictures.

It is common for members to use our text chat (instant messaging) system to communicate with each other in text chat-only sessions.
o	This text chat is also moderated, with the main processes being as follows: There is an automated process whereby all text chat is scanned using an algorithm which searches for specific keywords. The keywords are designed to detect, amongst other things, any suggestion that a conversation contains anything that might indicate illegal, under-age, coercive and non-consensual activity. If the automated process identifies any text chat that requires review by a member of the customer service team then a ticket is automatically generated.
o	The suspicious text chat is then reviewed by a customer service team member to decide whether any action is required. The matter is additionally reviewed by a senior team member and must be resolved to their satisfaction before the ticket can be closed