Content Moderation, Reporting and Removal

• Any person depicted in any Content can Request Content Removal.
• Whether or not you are a user of LinkPay, you can “Request Content Removal.”
• All reports will be reviewed and resolved within five (5) business days.
• Sellers can appeal any Content removal from the Platform.
• Any payment link Published to the Platform that violates LinkPay’s Terms of Use, will be taken down immediately and the associated seller account will be suspended or terminated depending on the severity of the violation.

1. Website

1.1. Anyone can request for Content to be removed via the Platform.

1.2. Navigate to the payment link you want to submit for removal.

1.3. Use the report control on the page.

1.4. Indicate that you are depicted in the Content and want it removed.

2. Email

2.1. Any person can submit a “Request for Content Removal” by emailing LinkPay at support@linkpay.co.

2.2. You will need to include your full legal name, date of birth, mailing address, phone number, and the Content URL or payment link for the Content you’re requesting be removed.

3. Mail

3.1. Any person can submit a “Request for Content Removal” by sending mail to our address:

Boink Technologies, Inc., a Delaware corporation
2045 Biscayne Blvd. Suite 118, Miami, FL 33137

3.2. You will need to include your full legal name, date of birth, mailing address, phone number, and the Content URL or payment link for the Content you’re requesting be removed.

Content Moderators will attempt to establish if the reported Content is illegal or in violation of the Platform’s Acceptable Use Policy within five (5) business days.

1. Identity Verification

1.1. Content Moderators will request an Identity Verification via Persona (if applicable).

1.2. The person requesting Content removal is given 48 hours to respond to the Identity Verification process or the request is rejected.

1.3. Persona Identity Verification Status:

1.3.1. “Completed” then Content Moderators will use the Identity to validate the veracity of the request.

1.3.2. “Failed” then the request is rejected.

1.3.3. “Expired” then the request is rejected.

2. Depiction Confirmation

2.1. Content Moderators will use the Identity Verification Photos to assess if the person requesting the removal is in fact the person depicted in the Content.

2.2. Depiction Confirmation Status:

2.2.1. “Match found” then Content Moderators will escalate the request to the seller.

2.2.2. “No match found” then the request is rejected.

3. Establish Legal Consent

3.1. Content Moderators will attempt to contact the seller and establish if proper consent was obtained under applicable law from the person depicted in the Content.

3.2. Outcomes:

3.2.1. If the person depicted in the Content is a verified co-creator who has signed the Co-Creator Agreement on LinkPay then legal consent is confirmed and the request is rejected.

3.2.2. If the seller obtained and kept on record prior written agreement from the co-creator that includes consent to be depicted in the Content, consent to allow for the public distribution of the Content and to Publish the Content to the Platform, and consent to have the Content downloaded, then legal consent is confirmed and the request is rejected.

3.2.3. If the seller fails to respond with recorded proof of written consent within 48 hours then the request is approved and the Content is removed immediately.

3.2.4. If the person requesting Content removal can provide proof that the consent previously provided is void under applicable law then the request is approved and the Content is removed immediately.

Email

1. Any person can submit an “Appeal of Content Removal” by emailing LinkPay at support@linkpay.co.
2. You will need to include your full legal name, mailing address, phone number, and the payment link that was taken down, which is named in the email you received notifying you of the removal.

Mail

1. Any person can submit an “Appeal of Content Removal” by sending mail to our address:

Boink Technologies, Inc., a Delaware corporation
2045 Biscayne Blvd. Suite 118, Miami, FL 33137

2. You will need to include your full legal name, mailing address, phone number, and the payment link that was taken down, which is named in the email you received notifying you of the removal.

Content Moderators will attempt to establish if the Content was removed in error by reviewing the decision made:

1. If the results of the investigation conclude that the Content was removed in error, Content Moderators will restore the payment link, restore the account, and remove the violation from the account’s record.
2. If the results of the investigation conclude that the Content was removed because they cannot establish if proper consent was obtained under applicable law from the person depicted in the Content, then the payment link will remain down.

If Content Moderators are unable to reach a conclusion that satisfies both parties, you may submit for such dispute to be finally settled in binding arbitration, the cost of such proceedings to be at LinkPay’s expense. The American Arbitration Association (“AAA”) will administer the arbitration in accordance with the Expedited Procedures named in Section 18 of the Terms of Use, and the arbitration will be held in the U.S. county where you live or the State of Florida, as set out there. Subject to the foregoing provisions of this section, the jurisdiction and venue for actions related to the subject matter hereof shall be the state and United States federal courts located in the State of Florida and both parties hereby submit to the personal jurisdiction of such courts.

If you are a user of LinkPay, you warrant (which means you make a legally enforceable promise) that you will not make any complaint under this Content Removal Policy which is wholly unjustified, abusive, or made in bad faith. If we determine that you have breached this warranty, we may suspend or terminate your Buyer Account and/or seller account.

1. Any person can report Content that may be illegal or violates the Platform’s Acceptable Use Policy.
2. Whether or not you are a user of LinkPay, you can “Report Illegal Content.”
3. All reports of illegal Content will be reviewed and resolved within five (5) business days.
4. Any payment link containing illegal Content or Content that violates the Platform’s Acceptable Use Policy will be taken down immediately and the seller’s account will be suspended or terminated depending on the severity of the violation.
5. Sellers can appeal any Content removal from the Platform.

Website

• Anyone can report Content via the web interface.
• Navigate to the payment link you want to report.
• Use the report control on the page.
• Choose one of the following reporting options from the menu:
  • Child Abuse
  • Animal Abuse
  • Non-consensual Acts
  • Illegal Activities and Regulated Goods
  • Sexual Solicitation
  • Bullying and Harassment
  • Scams or Fraud
  • Intellectual Property Infringement
  • Violence
  • Dangerous Groups and Individuals
  • Suicide, Self-Injury or Harm
  • Bodily Fluids
  • Private Information
  • Hateful Content

Email

• Any person can “Report Illegal Content” by emailing LinkPay Support at support@linkpay.co.
• Users will need to include their full legal name, mailing address, phone number, the Content URL or payment link you’re reporting, and the type of illegal Content or Acceptable Use Policy violation you’re reporting.

Mail

• Any person can “Report Illegal Content” by sending mail to our address:

Boink Technologies, Inc., a Delaware corporation
2045 Biscayne Blvd. Suite 118, Miami, FL 33137

• Users will need to include their full legal name, mailing address, phone number, the Content URL or payment link you’re reporting, and the type of illegal Content or Acceptable Use Policy violation you’re reporting.

We do not request copies of any videos or images you report. Please do not copy, save, download, share or send images or videos of suspected Child Sexual Abuse Material with LinkPay or any other persons. To report suspected Child Sexual Abuse Material, email 2257@linkpay.co.

Content Moderators will attempt to establish if the reported Content is illegal or in violation of the Platform’s Acceptable Use Policy within five (5) business days.

1. Reported Content Review: Content Moderators evaluate each reported payment link based on LinkPay’s Acceptable Use Policy and attempt to assess whether any of the media contains illegal materials and/or violates any of the Content Guidelines set forth in LinkPay’s Acceptable Use Policy.
2. Illegal Content: If the Content Moderator detects media containing any Child Abuse, Animal Abuse, Non-consensual Acts, Illegal Activities and Regulated Goods, Sexual Solicitation, or Dangerous Groups and Individuals (as such terms are described in our Acceptable Use Policy) then the payment link is immediately taken down and the seller’s account is terminated.
3. Violations of the Acceptable Use Policy: If the Content Moderator detects media that violates the Platform’s Acceptable Use Policy then the payment link is immediately taken down and the seller’s account will be suspended or terminated depending on the severity of the violation.
4. Approved Content: If the Content Moderator reviews the payment link and is unable to detect any violations of the Acceptable Use Policy or illegal media then the Report is removed from the seller’s account and the payment link remains on the Platform. No further actions are required by the seller.

Email

• Any person can submit an “Appeal of Content Removal” by emailing LinkPay at support@linkpay.co.
• You will need to include your full legal name, mailing address, phone number, and the payment link that was taken down, which is named in the email you received notifying you of the removal.

Mail

• Any person can submit an “Appeal of Content Removal” by sending mail to our address:

Boink Technologies, Inc., a Delaware corporation
2045 Biscayne Blvd. Suite 118, Miami, FL 33137

• You will need to include your full legal name, mailing address, phone number, and the payment link that was taken down, which is named in the email you received notifying you of the removal.

Content Moderators will attempt to establish if the Content was removed in error by reviewing the decision made:

1. If the results of the investigation conclude that the Content was blocked in error, Content Moderators will restore the payment link, restore the account, and remove the violation from the account’s record.
2. If the results of the investigation conclude that the Content was blocked because it contained content that is illegal or violates the Platform’s Acceptable Use Policy, then the payment link will remain down.

If you are a user of LinkPay, we may suspend or terminate your access to LinkPay if you “Report Illegal Content” in a way which is wholly unjustified, abusive, or made in bad faith, for example if you consistently report Content by the same seller that does not contain any violations of our Acceptable Use Policy.

1. Content Publishing is only permitted from verified sellers (see the Terms for Sellers).
2. Verify the age and identity of all sellers and co-creators (see the Terms for Sellers).
3. Verify the validity and possession of the sellers’ Government ID (see the Terms for Sellers).
4. Require all sellers and co-creators featured in Adult Content to review and agree to LinkPay’s Terms for Sellers and, in the case of co-creators, the Co-Creator Agreement.
5. Require all sellers to verify the identity and age of all co-creators. Sellers must be able to provide supporting documents upon request in accordance with the requirements for Adult Content and Non-Adult Content (see the Terms for Sellers).
6. Review all Content prior to Publication to ensure its legality and compliance with the Platform’s Acceptable Use Policy.
7. Any Content that may be illegal or violates the Platform’s Acceptable Use Policy, will be removed immediately and the seller’s account will be suspended or terminated depending on the severity of the violation.

1. Text Moderation

LinkPay sets forth a list of terms that are forbidden from use on the Platform in any manner whatsoever including captions, display names, handles, biographies, and payment link titles and descriptions (“Forbidden Terms”). LinkPay incorporates the Association of Sites Advocating Child Protection (ASACP) “Unacceptable Terms” list to combat Content that contains child exploitation materials or the depiction of nonconsensual activities:

Category	Forbidden terms
Non-consensual acts	asleep, abduction, capture, asphyxiation, chloroform, comatose, coma, coercion, doze, drinking, drunk, alcohol, booze, liquor, forced, hypnotization, incapacitation, immobilization, intoxicated, drugs, inebriation, wasted, kidnap, molest, paralyzed, rape, unconscious, passed out, unwilling, brainwashing, involuntary, trafficking, smuggling, violation, mind control, sedation, sleep, strangulation, exploitation, necrophilia, suffocation
Child abuse	CNC, chronophilia, ephebophilia, hebephilia, babies, age play, age regression, adolescent, children, childcp, jailbait, fetal, lolicon, lolita, minor, pedophilia, pedo, preteen, 4teen, forteen, 6teen, 7teen, teen 13, teen 14, teen 15, teen 16, teen 17, juvenile, kiddie, kid, kinderporn, kindersex, pedoland, pre-adolescent, preeteen, prelolitas, pre-teen, underage, young, infant, pederast
Bodily fluids	blood, bleeding, bloodplay, fecal, poop, poo, feces, watersports, hardsports, menstruation, pissing, piss, pee, peeplay, koprofgie, kotoran, scat, skat
Animal abuse	beastiality, crushing, zoophilia
Violence	abuse, cannibalism, choking, mutilation, snuff, torture, weaponry, brutality, killing, smothering, suicide, self injury, lynching, murder
Sexual solicitation	escort, fan fuck, fuckafan, hooker, meet, prostitution, pornstar experience, PSE
Racism and xenophobia	chink, coon, dago, dogan, gringo, golliwog, gyppie, jiggabo, kraut, kyke, ku lux klan, moulie, neche, nigga, nigger, paki, pikey, raghead, spic, whitey, wog
Incest	incest, incestuous themes

LinkPay automatically reviews all text that is published to the Platform to detect attempts to circumvent text moderation with alternative spellings or special characters. If Forbidden Terms are detected by or reported to LinkPay then the Content is removed immediately from the Platform. Some of these terms have legitimate uses, and using one triggers review by a person rather than an outright refusal. Violators’ accounts are suspended until further review, which may result in account termination and permanent banning.

2. Inappropriate or Offensive Content Identification, Removal and Reporting with Machine Learning

LinkPay screens all Content through Amazon Rekognition’s AI that analyzes each image and video by running state of the art Machine Learning (ML) which improves detection of novel CSAM, and any of the following:

1. Explicit Nudity
   1. Nudity
   2. Graphic Male Nudity
   3. Graphic Female Nudity
   4. Sexual Activity
   5. Illustrated Explicit Nudity
   6. Adult Toys
2. Suggestive
   1. Female Swimwear or Underwear
   2. Male Swimwear or Underwear
   3. Partial Nudity
   4. Barechested Male
   5. Revealing Clothes
   6. Sexual Situations
3. Violence
   1. Graphic Violence or Gore
   2. Physical Violence
   3. Weapon Violence
   4. Weapons
   5. Self-Injury
4. Visually Disturbing
   1. Emaciated Bodies
   2. Corpses
   3. Hanging
   4. Air Crash
   5. Explosions and Blasts
5. Rude Gestures
   1. Middle Finger
6. Drugs
   1. Drug Products
   2. Drug Use
   3. Pills
   4. Drug Paraphernalia
7. Tobacco
   1. Tobacco Products
   2. Smoking
8. Alcohol
   1. Drinking
   2. Alcoholic Beverages
9. Gambling
   1. Gambling
10. Hate Symbols
11. Nazi Party
12. White Supremacy
13. Extremist

Generated and Deepfake Content

Given that the Platform allows AI image uploads, all deepfake and non-consensual AI-generated content is prohibited. Such content includes any synthetic or manipulated media that depicts real individuals without their explicit consent. Detected deepfake or non-consensual AI content will be blocked from publication or removed immediately in accordance with the standard moderation process.

3. Content Moderation and Labeling with Human-in-the-loop Review

LinkPay’s trained content moderators manually review (based on LinkPay’s Acceptable Use Policy) any flagged Content from the Automated Content Moderation process. If the Human-in-the-loop Content Moderation process uncovers Content that is illegal or otherwise violates the Platform’s Acceptable Use Policy then it is blocked from being Published to LinkPay.

Email

1. Any person can submit an “Appeal of Content Removal” by emailing LinkPay at support@linkpay.co.
2. You will need to include your full legal name, mailing address, phone number, and the payment link that was taken down, which is named in the email you received notifying you of the removal.

Mail

1. Any person can submit an “Appeal of Content Removal” by sending mail to our address:

Boink Technologies, Inc., a Delaware corporation
2045 Biscayne Blvd. Suite 118, Miami, FL 33137

2. You will need to include your full legal name, mailing address, phone number, and the payment link that was taken down, which is named in the email you received notifying you of the removal.

Content Moderators will attempt to establish if the Content was removed in error by reviewing the decision made:

1. If the results of the investigation conclude that the Content was blocked in error, Content Moderators will restore the payment link, restore the account, and remove the violation from the account’s record.
2. If the results of the investigation conclude that the Content was blocked because it contained content that is illegal or violates the Platform’s Acceptable Use Policy, then the payment link will remain down.

Independent review of a disagreement

If, after LinkPay’s internal appeal review, the person who appealed and LinkPay still disagree about the outcome of a content-removal, account-action, or Acceptable Use Policy decision, either party may refer that remaining disagreement to a neutral independent review body.

The independent review body will be an unaffiliated third party that is not LinkPay, not the seller, and not the person who submitted the appeal. LinkPay will appoint that reviewer from a panel of independent trust-and-safety or dispute-resolution professionals. The reviewer will consider the original decision, the appeal file, and LinkPay’s Acceptable Use Policy and this Content Moderation, Reporting and Removal policy, and will issue a written determination. LinkPay will implement that determination.

LinkPay, as the merchant of record, will bear the fees and costs of that independent review. Each party remains responsible for its own attorneys’ fees unless the reviewer directs otherwise.

This independent review does not apply to Content that LinkPay has determined is illegal, including child sexual abuse material or other Content that LinkPay is required to preserve, report, or withhold under applicable law. Those matters are reported to the appropriate authorities and are not restored through internal appeal or independent review.

Nothing in this section limits a person’s right to report Content to law enforcement, or LinkPay’s right to seek court relief to stop an ongoing legal violation.

1. Provide third-party vendors monthly reports that list all Content reported as illegal, in violation of the Platform’s Acceptable Use Policy, or requested to be removed.
2. Provide third-party vendors a breakdown of all the relevant actions taken to resolve user reports of misconduct or requests for Content removal.
3. Provide third-party vendors account credentials to access and view all paywalled Content for the audit and review of all compliance processes and procedures.

1. LinkPay tracks every report and every removal request, and the Monthly Compliance Report is generated from that record. Each line of the report carries:
   1. Report ID: A reference ID for the report
   2. Status: The current status of the report
      1. open
      2. in review
      3. resolved
      4. dismissed
   3. Report Reason:
      1. Child Abuse
      2. Animal Abuse
      3. Non-consensual Acts
      4. Illegal Activities and Regulated Goods
      5. Sexual Solicitation
      6. Bullying and Harassment
      7. Scams or Fraud
      8. Intellectual Property Infringement
      9. Violence
      10. Dangerous Groups and Individuals
      11. Suicide, Self Injury or Harm
      12. Bodily Fluids
      13. Private Information
      14. Hateful Content
   4. Type and Item ID: Whether the reported item is a payment link or a profile, and its identifier
   5. URL: The URL for the payment link or profile page being reported or requested for removal
   6. Created at Date: A timestamp of when the report was created
   7. Resolution: The actions taken, which will be recorded and include (more than one may apply over the life of a report)
      1. Content Removed
      2. User Suspended
      3. Reported to Authorities
      4. No Violation
      5. Escalated
   8. Admin URL: Where the reported item can be reviewed in our moderation console
2. LinkPay will generate and share the Monthly Compliance Report with all third-party vendors on the first business day of each month.
3. LinkPay will create and provide all third-party vendors account credentials to access and view all paywalled Content for the audit and review of all compliance processes and procedures.

In addition to the reporting set out in this policy, LinkPay will also, where required by applicable law or where LinkPay deems it necessary, report Content that is illegal to the applicable authorities or law enforcement agency.