Legal Document

Content Moderation Policy

This policy sets out the standards for content on SGSuperFans, the categories of prohibited and restricted content, the systems we use to identify and review violations, the consequences for non-compliance, and the rights of users throughout our enforcement and appeals process.

Effective: January 1, 2026Last Updated: March 2026Version 2.0Reviewed Quarterly
Platform Standards: SGSuperFans is a creator economy platform that supports free expression, artistic creativity, and adult content within clearly defined limits. This policy exists to protect our community, comply with applicable law, and maintain the integrity of the platform. All users are bound by these standards from the moment they create an account or access our services.
Overview

1.Policy Overview and Purpose

SGSuperFans Inc. operates a premium creator economy platform through which creators publish content, set subscription tiers and pay-per-view prices, conduct live streams, accept tips and gifts, and communicate with fans through direct messaging. Fans subscribe, purchase content, book creator services, and participate in live experiences. The platform processes significant volumes of user-generated content daily across a global user base.

This Content Moderation Policy is the foundational document governing what content is permitted, what is prohibited, how violations are identified and reviewed, what consequences apply, and how users can challenge decisions affecting their accounts. It is written to be clear and navigable by creators, fans, legal counsel, regulators, and law enforcement agencies.

The Four Principles Guiding This Policy

  • Legality: All content on the platform must comply with the laws of the user's jurisdiction and the laws applicable to our operations. We do not treat legal compliance as a ceiling; we treat it as a floor.
  • Fairness: Enforcement decisions are made consistently, without discrimination based on the identity of the user, the viewpoint expressed, or the commercial value of an account to the platform. The same rules apply to all users equally.
  • Proportionality: Enforcement actions are calibrated to the severity and nature of the violation. A first minor breach does not carry the same consequence as repeated or serious violations. We distinguish between content that requires removal and content that requires restriction.
  • Transparency: Users are informed of enforcement decisions, provided with the applicable policy basis, and given a meaningful opportunity to appeal. We publish an annual transparency report disclosing aggregate enforcement data.

What This Policy Is Not

This policy is not a guarantee of any particular content remaining on the platform indefinitely. Platform standards evolve in response to legal developments, technological change, and community feedback. We reserve the right to update this policy at any time with notice to users. This policy does not create a private right of action between users, and it does not limit any rights users may have under applicable law independently of the platform.

This policy should be read alongside our Terms of Service, Privacy Policy, and Community Guidelines. In the event of any conflict between this policy and another document, the Terms of Service governs unless this policy expressly states otherwise for a specific provision.
Overview

2.Scope of Application

This policy applies to all content transmitted through or stored on the SGSuperFans platform, regardless of the content format, the subscription tier at which it is published, or the geographic location of the user who uploaded it.

Content Types Covered

  • Posts, stories, reels, and photo albums published to a creator profile
  • Pay-per-view and premium subscription content of any format
  • Direct messages, group messages, and paid message threads
  • Live stream video and audio, including archived recordings
  • Shoutout recordings and personalized video messages
  • Event listings, event descriptions, and event promotional materials
  • Playlists, collections, and curated content bundles
  • Profile bios, display names, usernames, and profile images
  • Thumbnails, captions, hashtags, and metadata attached to any content
  • Comments, reactions, and public responses to creator content
  • Links shared within the platform to external resources

Users Covered

  • Creators: All registered creator accounts, regardless of verification status, subscription tier structure, or revenue level
  • Fans: All registered fan accounts, including free-tier and paying subscribers
  • Agency and business accounts: Accounts operating on behalf of creators or managing creator content under agency agreements
  • Visitors: Unregistered users accessing publicly available content through the platform website or app

Platforms Covered

  • The SGSuperFans web application accessible at sgsuperfans.com
  • Native iOS and Android mobile applications
  • Any authorized API integrations or embedded players
Content that is removed under this policy does not automatically restore a creator's eligibility for monetization features, verification status, or any other platform feature that was conditioned on compliance with platform standards.
Overview

3.Governing Legal Framework

SGSuperFans Inc. is incorporated and headquartered in Ontario, Canada. Our legal obligations arise from Canadian federal and provincial law, and we additionally monitor and comply with applicable international law as it affects users in the jurisdictions where we operate. The following legal instruments directly govern our content obligations.

Canadian Federal Law

  • Criminal Code of Canada: Section 163.1 (child pornography, mandatory reporting and non-possession obligations); Section 162.1 (non-consensual distribution of intimate images); Section 319 (public incitement of hatred, wilful promotion of hatred); Section 264 (criminal harassment); Section 380 (fraud and false pretenses); Section 83.2 (facilitating terrorist activity)
  • Copyright Act (R.S.C., 1985, c. C-42): Governs takedown obligations and safe harbor for hosting platforms; our DMCA-equivalent procedures are designed to comply with this Act
  • Personal Information Protection and Electronic Documents Act (PIPEDA) and Bill C-27: Governs the collection, use, and disclosure of personal data in content moderation and reporting processes
  • Canada's Anti-Spam Legislation (CASL): Governs commercial electronic messages, unauthorized software installation, and deceptive electronic communications
  • Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211): Informs our safeguarding obligations with respect to trafficking and exploitation content

Ontario Provincial Law

  • Ontario Human Rights Code: Governs content that constitutes an infringement of the right to be free from discriminatory harassment and hate speech
  • Consumer Protection Act, 2002 (Ontario): Governs deceptive practices in subscription and commercial transactions conducted through the platform

International Law and Foreign Obligations

  • US Digital Millennium Copyright Act (DMCA, 17 U.S.C. 512): Our DMCA takedown procedures follow this framework as the internationally recognized standard for copyright notice and counter-notification
  • European Union Digital Services Act (DSA) and GDPR: Applied to the extent required for EU-resident users accessing the platform
  • United Kingdom Online Safety Act 2023: Applied to the extent required for UK-resident users, including illegal content duties and child safety duties
  • UN Convention on the Rights of the Child (UNCRC): Informs our child safety standards and zero-tolerance approach to CSAM
  • Budapest Convention on Cybercrime: Governs our cooperation with law enforcement in cross-border cybercrime investigations

Reporting Obligations

  • Mandatory reporting of known or suspected child sexual abuse material to the National Center for Missing and Exploited Children (NCMEC) CyberTipline and to the Canadian Centre for Child Protection (Cybertip.ca)
  • Cooperation with lawful requests from Canadian law enforcement, court orders, and applicable international mutual legal assistance treaty (MLAT) requests
  • Reporting of imminent threats of violence or terrorism to relevant Canadian authorities and, where applicable, international law enforcement agencies
Prohibited

4.Absolute Prohibitions

The following categories of content are prohibited in all circumstances on the SGSuperFans platform. There are no exceptions based on artistic intent, fictional framing, prior consent between parties, subscription tier, account standing, verification status, or any other factor. Violations result in immediate content removal, account termination, and in most cases referral to law enforcement.

These prohibitions are non-negotiable. Platform staff have no discretion to waive, reduce, or delay enforcement of the absolute prohibitions listed in this section. Any content in these categories will be removed within hours of detection and the account will be permanently terminated.

Zero Tolerance Categories

  • Child sexual abuse material (CSAM): Any content of any format (photographic, video, audio, animated, drawn, computer-generated, or AI-generated) that depicts a minor in a sexually explicit or suggestive context. This includes content where the depicted individual is presented or described as a minor regardless of their actual age.
  • Human trafficking and sexual exploitation: Content that solicits, recruits, facilitates, advertises, or promotes the trafficking of persons for sexual exploitation, forced labour, debt bondage, or any other form of servitude. This includes coded language and indirect solicitation designed to obscure trafficking intent.
  • Terrorism and mass violence: Content that constitutes terrorist propaganda, actively recruits for a designated terrorist entity, glorifies or celebrates acts of mass violence, or provides operational support for planned attacks.
  • Weapons of mass destruction: Detailed technical instructions for synthesizing biological, chemical, nuclear, or radiological weapons, or for modifying conventional weapons to cause mass casualties.
  • Non-consensual intimate imagery (NCII): Intimate images or recordings of an identifiable real person shared without that person's free and informed consent, including images originally shared in a private context.
  • Coercion and blackmail: Content that threatens to release intimate images, private information, or other sensitive material unless the target complies with financial or other demands.
  • Doxxing with intent to harm: Publication of a specific individual's private identifying information (home address, phone number, financial details, family member identities) combined with an explicit or implicit call for others to act against that individual.
  • Real-world torture, murder, and extreme graphic violence: Authentic footage of torture, execution, or graphic mutilation of living persons shared for entertainment, recreation, or shock value rather than a clear legitimate journalistic purpose.
Prohibited

5.Adult and Explicit Content

SGSuperFans is a platform that permits adult content produced and distributed by verified adult creators to verified adult fans. The permissions in this section exist because we respect the right of consenting adults to create and access legal adult material. Those permissions are bounded by strict safeguards that no creator or fan may circumvent.

Conditions for Publishing Adult Content

  • The creator must have completed age verification (minimum 18 years of age) through our third-party identity verification provider before the adult content category is enabled on their account
  • Every piece of adult or sexually explicit content must be designated as adult content in the post settings at the time of upload; the platform will not accept any claim that an adult designation was not required for a specific piece of explicit content
  • Content depicting any identifiable real person in a sexual context requires that person's documented affirmative consent to the specific content and to its publication on this platform; the creator must retain that documentation and provide it to the platform upon request
  • Content must have been produced lawfully in the jurisdiction where it was produced, with all performers having provided valid consent under applicable law

Age Verification for Fans

Adult content is age-gated at the fan level. Fans must complete age verification confirming they are at least 18 years of age before the platform enables access to any adult-category content. The platform uses a third-party identity verification layer for this purpose. Fans who provide false age information to bypass this gate are in material breach of the Terms of Service and may be subject to account termination and legal action.

Absolute Limits Within the Adult Category

The following content is prohibited in all circumstances, including within the adult content category, and will never be permitted on the platform regardless of purported consent between the creator and fan:

  • Any sexual content involving a person who is a minor or is depicted or described as a minor, regardless of claimed artistic intent, fictional framing, or animation format
  • Any sexual content depicting a non-consenting party, including content where the absence of consent is presented as part of the content's appeal without clear mutual pre-arranged context and documented consent of all depicted parties
  • Bestiality and sexual content involving animals
  • Content that sexualizes gore, mutilation, death, or torture
  • Content specifically designed to humiliate or degrade another identifiable real person without their documented consent to the specific depiction and its distribution on this platform

Creator Responsibilities

  • Creators bear full and exclusive responsibility for the legality of all adult content they upload, including age verification, consent, and compliance with production law
  • The platform does not produce, direct, endorse, or pre-screen adult content; all editorial decisions are made by the creator
  • The platform may require creators to provide age verification documentation and consent records for any content upon request and may remove content pending verification
Publishing adult content that violates any condition in this section will result in immediate content removal, account suspension pending investigation, and potential permanent account termination. Cases involving minors or non-consensual content will be referred to law enforcement.
Prohibited

6.Hate Speech and Discrimination

SGSuperFans prohibits content that dehumanizes individuals or groups on the basis of protected characteristics, promotes hatred toward those groups, or incites violence or discrimination against them. This prohibition is rooted in our legal obligations under the Criminal Code of Canada and the Ontario Human Rights Code, as well as our core commitment to maintaining a platform where creators and fans from all backgrounds can participate with dignity.

Protected Characteristics

The following characteristics are protected under this policy: race, colour, ethnicity, national or ethnic origin, ancestry, indigenous identity, religion or creed, sex, gender, gender identity, gender expression, sexual orientation, disability, age, immigration status, and social origin.

Prohibited Content

  • Content that portrays persons of a protected group as subhuman, inherently inferior, or unworthy of equal dignity and legal protection
  • Content that calls for, glorifies, or celebrates violence, discrimination, or the denial of rights against persons because of a protected characteristic
  • Neo-Nazi symbols, imagery, and propaganda; white supremacist and ethnonationalist manifestos and recruiting material; calls for genocide or ethnic cleansing
  • Content that denies or minimizes historically documented genocides for the purpose of promoting hatred against the targeted group
  • Content that stereotypes an entire group in a way designed to incite hatred rather than engage in legitimate social commentary

Permitted Content

  • Educational, journalistic, documentary, and academic content that discusses hate speech, historical atrocities, or discrimination for the purpose of understanding, critiquing, or countering them
  • Counter-speech content that directly engages with, refutes, or exposes hateful ideologies
  • Artistic and satirical content that critiques power structures, systemic inequality, or discrimination, when the content's purpose is clearly critical rather than promotional
  • Personal testimony from individuals sharing their experiences of discrimination or hate

Where content falls in a genuinely ambiguous zone between protected expression and prohibited hate speech, our Trust and Safety team applies a contextual analysis considering the creator's stated purpose, the surrounding content, the likely audience, and the reasonable interpretation of the content by a person in the targeted group.

Platform enforcement in this area is subject to review under the Ontario Human Rights Code and the Criminal Code of Canada. Content that constitutes wilful promotion of hatred against an identifiable group under Section 319 of the Criminal Code will be reported to law enforcement.
Prohibited

7.Harassment and Abusive Conduct

SGSuperFans is committed to providing a platform where creators can build audiences and fans can engage with creators without being subjected to targeted abuse, threats, or sustained unwanted conduct. This section covers both content published on the platform and conduct directed through the platform's communication features.

Prohibited Conduct

  • Targeted harassment: Publishing content or sending messages that single out a specific individual with repeated, unwanted, hostile, or abusive material designed to intimidate, distress, or silence them
  • Credible threats of violence: Threats of physical violence, sexual violence, or serious bodily harm directed at a specific identifiable person, whether communicated publicly or privately through the platform
  • Doxxing with intimidation intent: Publishing private identifying information about an individual (home address, phone number, workplace, family members' identities) with the intent to facilitate harassment or harm
  • Coordinated abuse: Organizing or participating in coordinated efforts by multiple accounts to mass-report, mass-message, or mass-post abusive content targeting a specific individual
  • Stalking behavior: Continuing to contact, follow, or monitor a user who has blocked or restricted the harassing party; creating new accounts to circumvent a block
  • Sexual harassment: Sending unsolicited explicit content, sexually threatening messages, or persistent sexual propositions after the recipient has indicated they are unwelcome
  • Harassment of platform staff: Abuse, threats, or coordinated targeting of SGSuperFans employees, contractors, and Trust and Safety team members in connection with platform operations

Tools Available to Users

  • Block: prevents the blocked user from viewing your profile or contacting you
  • Mute: hides content from a user without notifying them
  • Restrict: limits a user's ability to interact with your content
  • Keyword filters: automatically hide comments or messages containing specified words
  • Report: flags content or conduct for Trust and Safety review

Context and Proportionality

Not all critical, harsh, or offensive content constitutes harassment. Strong criticism, negative reviews, artistic content that challenges or provokes, and expression of disagreement are not prohibited under this section. Enforcement requires evidence of targeting, intent to harm, and conduct that goes beyond the expression of a viewpoint. Repeated minor incidents that individually fall below the threshold may cumulatively constitute harassment when reviewed together.

Prohibited

8.Misinformation and Deceptive Practices

SGSuperFans does not function as a general news publisher and does not make editorial judgments about political opinions, contested facts, or disputed scientific questions. However, we do act to address content that poses a direct risk of physical harm to users or that involves deliberate deception with financial consequences for users of the platform.

Health Misinformation

  • False claims that a specific product, supplement, or practice prevents, treats, or cures a serious disease that are presented as established medical fact and could cause users to forgo effective treatment or engage in dangerous behavior
  • Advice recommending dangerous dosages or combinations of substances with a reasonable potential to cause serious physical harm
  • Content specifically targeting individuals in identified vulnerable health situations with false miracle cure claims

Deceptive Commercial Practices

  • False or misleading subscription pricing: advertising a subscription tier at one price and charging fans a different price at checkout without clear disclosure of the discrepancy
  • Fake investment schemes, unlicensed financial advice presented as guaranteed returns, and promotional content for Ponzi or pyramid structures directed at users of the platform
  • Phishing content: links or pages designed to harvest user credentials, payment information, or personal data under false pretense of being legitimate platform features
  • Fabricated endorsements: presenting a public figure's words, likeness, or identity as an endorsement of a product, service, or platform without their consent

Fabricated Content

  • Fabricated quotes or statements attributed to identifiable real persons, presented as authentic, in contexts designed to damage their reputation or to deceive users into a false belief about that person's views
  • Coordinated inauthentic behavior: operating networks of fake accounts designed to manipulate platform metrics, trending content, or audience perception of public opinion

What Is Not Restricted

Satire, parody, fiction, artistic speculation, opinion, and commentary are not restricted under this section when they are clearly labeled or contextually obvious as non-factual. Platform users retain the right to express health-related opinions, share personal experiences, and critique established consensus without those expressions being classified as misinformation.

For borderline content that contains disputed claims without rising to the level of a removal-worthy violation, the platform may apply a content advisory label rather than remove the content. Labels are applied by the Trust and Safety team and are subject to the same appeals process as removals.
Integrity

9.Spam and Manipulation

The integrity of the SGSuperFans platform depends on authentic engagement between creators and fans. The platform actively detects and removes inauthentic behavior that artificially distorts follower counts, subscriber numbers, content engagement metrics, and earnings figures, as these distortions undermine the trust of all users and the value of the platform as a whole.

Prohibited Behaviors

  • Metric inflation: Artificially inflating followers, subscribers, likes, tips, views, or any other platform metric through purchased bot traffic, third-party engagement services, exchange rings, or coordinated fake accounts
  • Automated mass messaging: Sending bulk, automated, or templated direct messages for commercial solicitation without the recipient's prior consent or as part of an unsolicited marketing campaign
  • Undisclosed automation: Operating bots, scripts, or automation tools that simulate human engagement, generate content, or perform account actions without disclosing the automated nature of the activity where material to a user's interaction with that activity
  • Phishing and credential harvesting: Sharing links, redirects, or embedded content designed to trick users into disclosing login credentials, payment card information, or personal identifiable information
  • Fake giveaways: Conducting contests or giveaways whose primary purpose is to harvest user data, personal information, or financial details rather than to provide the advertised reward
  • Off-platform payment circumvention: Soliciting payments from fans outside the platform in order to avoid platform fee structures, where that solicitation occurs through platform communications

Detection Systems

The platform uses automated systems to detect spam signals including message volume and velocity, link pattern analysis, account age and registration behavior, engagement anomalies, behavioral fingerprinting, and network analysis identifying coordinated account clusters. Accounts flagged by automated detection are reviewed by Trust and Safety before enforcement action is taken where technically feasible.

Permitted Automation

Creators using legitimate scheduling tools, content management integrations, or approved API features are permitted to use those tools. When required by separate platform guidelines, creators must disclose the use of automation tools to fans where that use is material to the fan's experience.

Integrity

10.Impersonation and Identity Fraud

Users of SGSuperFans interact with one another with a reasonable expectation that accounts represent who they say they are. Impersonation causes direct harm: it misleads fans into paying money to a fake account, damages the reputation of the real person being impersonated, and erodes trust across the platform.

Prohibited Conduct

  • Creating a profile that misrepresents the account holder as a specific real person, public figure, brand, or organization without that party's express authorization, in a manner likely to deceive users
  • Impersonating SGSuperFans Inc., any SGSuperFans employee, or any official platform function (such as a fake Trust and Safety notification or a fake system alert) in any communication
  • Creating an account with a name, profile image, or identifier designed to cause users to confuse the account with a verified creator, public figure, or recognized brand
  • Falsely claiming platform verification, official partnership status, or any form of affiliation with SGSuperFans or any third party
  • Identity theft and unauthorized account access: accessing another user's account without authorization, or using stolen credentials to operate or extract value from another user's account

Permitted Accounts

  • Fan accounts and tribute accounts: Accounts dedicated to celebrating a public figure or creator that are clearly and prominently labeled as unofficial fan accounts (e.g., "Fan Account" in the display name or bio)
  • Parody accounts: Accounts that satirize or parody a real person or entity, provided the account is clearly labeled as a parody and does not publish content designed to genuinely deceive users into believing it is operated by the subject of the parody
  • Stage names and personas: Accounts operating under a stage name, artistic alias, or creative persona that does not falsely claim association with another identifiable real person
Identity theft involving financial fraud (such as impersonating a creator to collect subscription payments or tips) will be referred to law enforcement and is subject to civil legal action by the affected party.
Integrity

11.Intellectual Property

SGSuperFans respects the intellectual property rights of creators, third parties, and rights holders globally. The platform operates in compliance with the Canadian Copyright Act, the US Digital Millennium Copyright Act, and equivalent international copyright law frameworks. Creators assume full legal responsibility for the originality and ownership of all content they upload.

Copyright Takedown Process

Rights holders may submit a copyright takedown notice to legal@sgsuperfans.com. A valid notice must include all of the following elements:

  • Identification of the copyrighted work claimed to be infringed, with sufficient detail to locate it
  • Identification of the infringing content on the platform, including the URL or post identifier and the specific portion of the content that infringes
  • Contact information for the rights holder or their authorized agent
  • A statement of good faith belief that the use of the material is not authorized by the copyright owner, their agent, or the law
  • A statement, made under penalty of perjury, that the information in the notice is accurate and that the notifying party is authorized to act on behalf of the copyright owner
  • Physical or electronic signature of the rights holder or authorized agent

Counter-Notification Process

A creator whose content has been removed in response to a takedown notice may submit a counter-notification to legal@sgsuperfans.com within 14 business days of the removal notice. The counter-notification must include: identification of the removed content and its prior location; a statement under penalty of perjury that the removal was made by mistake or misidentification; consent to the jurisdiction of the Federal Court of Canada or equivalent court; and the creator's contact information. Upon receipt of a valid counter-notification, the platform may restore the content within 10 to 14 business days unless the notifying rights holder obtains a court order.

Repeat Infringer Policy

Creators who receive three or more valid, undisputed copyright takedown notices within any rolling 12-month period will have their accounts permanently terminated. This policy applies regardless of account revenue, subscriber count, or tenure on the platform.

Trademark Infringement

Content that uses another party's registered trademark in a manner likely to cause consumer confusion as to the source, sponsorship, or affiliation of goods or services is prohibited. Trademark disputes should be addressed to legal@sgsuperfans.com.

AI-Generated Content

Creators use AI tools at their own legal risk. The creator is solely responsible for ensuring that any AI-generated content they upload does not infringe third-party intellectual property rights. The platform does not assume any responsibility for infringement by AI-generated content, and the creator assumes full indemnification obligations toward the platform in such cases.

Creator warranties: by uploading any content, creators represent and warrant that they own or hold all necessary rights, licenses, consents, and permissions to upload, publish, and monetize that content on this platform, and that doing so does not infringe any third-party rights.
Safety

12.Child Safety and CSAM

SGSuperFans maintains an absolute, unconditional, and non-negotiable zero-tolerance policy toward child sexual abuse material (CSAM) and any content that sexualizes minors, regardless of format, purported fictional framing, artistic intent, or claimed consent. This is the most serious category of prohibited content on the platform.

Definition

CSAM includes any image, video, audio, animation, illustration, computer rendering, or AI-generated depiction of a minor (a person under 18 years of age) in a sexually explicit or sexually suggestive context. The prohibition applies with equal force to content where the depicted individual is presented or described as a minor regardless of their claimed age, and to content described as fictional, animated, or artistic.

Mandatory Response Protocol

Upon detection of CSAM through any means (automated hash-matching, user report, internal discovery, or law enforcement notification), SGSuperFans will immediately:

  • Remove the content and suspend the associated account pending investigation
  • Preserve all available evidence including account data, IP logs, and metadata in accordance with applicable preservation law
  • Report the content to the NCMEC CyberTipline as required under 18 U.S.C. 2258A (where applicable)
  • Report to the Canadian Centre for Child Protection at Cybertip.ca
  • Cooperate fully with law enforcement in all relevant jurisdictions without requiring a court order for legally mandated disclosures
  • Permanently ban the account holder and take all commercially reasonable steps to prevent re-registration by the same individual

Detection Technology

The platform uses PhotoDNA hash-matching technology to scan uploaded content against databases of known CSAM maintained by NCMEC and the Canadian Centre for Child Protection. Detection is proactive and operates prior to content being made available to other users where technically feasible. Additional machine learning classifiers supplement hash-matching for novel content not yet in known databases.

Age Verification Infrastructure

  • All creators must complete identity verification confirming they are at least 18 years of age before publishing any content; adult content cannot be enabled on an account until verification is complete
  • All fans must complete age verification before accessing any age-gated adult content
  • Age verification is performed through an independent third-party identity verification provider; verified age data is stored securely and not retained beyond the period required for compliance

Grooming and Minor-Targeting Content

Content designed to facilitate the grooming of minors, to normalize adult-child intimate relationships, or to solicit contact with minors outside the platform is prohibited and referred to law enforcement. This includes content that uses coded language or indirect framing to make such solicitation less visible to automated systems.

Reporting

Report suspected CSAM or child exploitation immediately to safeguarding@sgsuperfans.com and to your local law enforcement agency or national reporting body (NCMEC CyberTipline in the US; Cybertip.ca in Canada).

Safety

13.Non-Consensual Intimate Imagery

Non-consensual intimate imagery (NCII) is one of the most severe forms of platform abuse and causes profound psychological, social, and economic harm to victims. SGSuperFans prohibits NCII in all circumstances and operates specific infrastructure to respond to and prevent it.

Definition

NCII means any intimate, sexual, or explicitly private image or recording of a real identifiable person that is shared, distributed, or published without that person's free and ongoing informed consent to its distribution through this platform. This includes:

  • Images or videos originally shared in a private or consensual context that are later redistributed without ongoing consent
  • Images or recordings taken without the subject's knowledge or consent
  • AI-generated, digitally manipulated, or deepfake intimate images depicting a real identifiable person realistically
  • Intimate images shared as a form of revenge, coercion, blackmail, or intimidation

Legal Framework

NCII distribution is a criminal offence in multiple jurisdictions where our users operate. In Canada, it is criminalized under Section 162.1 of the Criminal Code, carrying a maximum sentence of five years imprisonment. The UK Online Safety Act 2023 creates obligations for platforms to address NCII. Multiple US states have enacted criminal statutes addressing non-consensual pornography. The platform cooperates fully with law enforcement in all such jurisdictions and does not require a court order to comply with lawful requests in connection with NCII investigations.

Victim Support and Reporting

  • Persons depicted in NCII should contact safety@sgsuperfans.com immediately; the platform targets full content removal within 24 hours of a verified report
  • StopNCII.org participation: SGSuperFans participates in the hash-sharing database operated by StopNCII.org. Victims may proactively submit intimate images at stopncii.org to generate a unique hash fingerprint; that fingerprint is shared with participating platforms, including SGSuperFans, which will automatically block any upload matching the fingerprint without the platform ever viewing the original image
  • Emergency resources: Cyber Civil Rights Initiative (cybercivilrights.org) provides crisis support and victim advocacy for NCII survivors

Creator Consent Obligations

A creator who publishes content depicting another identifiable person in any intimate, sexual, or private context must hold documented affirmative consent from that person that specifically covers: (a) the creation of the content, (b) its publication on this platform, and (c) its availability to the creator's subscriber base or pay-per-view purchasers. Providing false consent documentation to the platform is grounds for immediate permanent account termination and referral to law enforcement.

Safety

14.Content Involving Real Persons

Content on SGSuperFans frequently references, depicts, discusses, or involves real identifiable persons. This section sets out the standards that apply to such content beyond the specific prohibitions covered in other sections of this policy.

Defamation

Creators may not publish false statements of fact about real identifiable persons that are presented as true and that could damage that person's reputation. Expression of opinion, satire, and parody do not constitute defamation when properly framed and contextually apparent. The platform does not adjudicate defamation disputes between non-platform parties but will respond to court orders requiring content removal.

Privacy Rights

Creators may not publish private information about a real person that they did not consent to have disclosed, including medical records, financial accounts, home addresses, private communications, and information about family members not themselves in the public domain.

Deepfakes and AI-Generated Likenesses

  • Prohibited: AI-generated, digitally altered, or synthetic media that realistically depicts a real identifiable person saying or doing something they did not actually say or do, in a sexual context, a violent context, a context designed to solicit financial gain through false association, or a context intended to damage that person's reputation through fabrication, without the explicit consent of the depicted person
  • Permitted: Clearly labeled satirical or artistic deepfakes that are not sexually explicit, do not constitute defamation, and are marked clearly and conspicuously as AI-generated or synthetic content

Right of Publicity and Commercial Use

Creators may not use another real person's name, likeness, voice, performance, or persona in commercial content (including subscription content, pay-per-view content, brand sponsorships, or paid promotional material) without that person's documented authorization. Unauthorized commercial use of a celebrity, athlete, or public figure's identity in monetized content exposes the creator to civil liability and may result in platform enforcement action.

Public Figures vs. Private Individuals

Public figures have accepted greater scrutiny of their public roles and public conduct. Commentary, criticism, satire, and parody of public figures on matters of public concern is protected expression and is evaluated under a more permissive standard. Private individuals, who have not voluntarily entered public life, are entitled to stronger privacy protections, and content targeting private individuals is reviewed under stricter standards.

Disputes between users involving defamation, right of publicity, or privacy claims may require the affected party to seek independent legal advice and pursue remedies through a court of competent jurisdiction. The platform will cooperate with lawful orders and process served through proper legal channels.
Enforcement

15.Content Review and Moderation

SGSuperFans operates a multi-layer content moderation system combining automated detection technology with human review to identify policy violations promptly and accurately. The system is designed to prioritize the most serious harms while maintaining proportionate review for less severe violations.

Automated Detection

  • Hash-matching (PhotoDNA): All uploaded images and videos are scanned against databases of known CSAM maintained by NCMEC and the Canadian Centre for Child Protection; matching content is blocked prior to publication
  • Machine learning classifiers: AI-based classifiers evaluate content for spam signals, hate speech patterns, inauthentic behavior indicators, and other prohibited content categories
  • Link scanning: Outbound links shared on the platform are checked against databases of known malicious URLs, phishing pages, and illicit content repositories
  • Behavioral analysis: Account activity patterns are monitored for mass messaging, bot-like behavior, coordinated account clusters, and metric manipulation signals
  • Audio and video fingerprinting: Published content is compared against copyright fingerprint databases where technical implementation is available to identify known infringing material

User Reporting

Every piece of content on the platform includes an accessible Report function. Users may report content across the following categories: CSAM; NCII; human trafficking; hate speech; harassment or threats; graphic violence; spam or fraud; impersonation; copyright infringement; and other policy violation. Reports are queued by category priority and reviewed by our Trust and Safety team.

Human Review

  • All CSAM, NCII, terrorism, and trafficking reports are reviewed by designated senior Trust and Safety officers and are never delegated to junior reviewers without oversight
  • Borderline automated flags are passed to human review before enforcement action is taken where technically feasible; the goal is to minimize false positives that incorrectly remove lawful content
  • Human reviewers undergo specialized training in applicable legal standards, trauma-informed review practices, and platform enforcement protocols
  • Mental health support resources, including regular psychological debriefs, are made available to all members of the Trust and Safety team

Review Prioritization

  • Priority 1 (target: within 2 hours): CSAM and NCII
  • Priority 2 (target: within 4 hours): trafficking, credible violence threats, terrorism
  • Priority 3 (target: within 48 hours): all other reported violations

Transparency

SGSuperFans publishes an annual transparency report disclosing content removals by category, law enforcement requests received, appeals filed, and appeal outcomes. The report is published on the platform's legal documentation page.

Enforcement

16.Enforcement Actions

Enforcement actions are calibrated to the nature, severity, and recurrence of the policy violation. The escalation framework below describes the range of available measures and the circumstances under which each applies.

Warning

Issued for first-time minor violations where the content does not pose a serious immediate risk. The creator is notified with a description of the violation, the applicable policy provision, and guidance on how to comply. Content may or may not be removed at this stage depending on severity.

Content Removal

The specific violating content is removed from the platform. The creator is notified of the removal, the policy basis, and their right to appeal. Account-level restrictions may or may not accompany a single content removal on a first offence.

Content Restriction

Applicable to content that is not prohibited for all users but requires additional safeguards (such as adult content that was not properly labeled). The content is moved to age-gated access rather than removed. The creator retains access to the content and can correct the issue.

Feature Restriction

Temporary suspension of one or more specific platform features (posting, direct messaging, live streaming, monetization functions) pending review or as a consequence of a moderate violation. The creator retains access to their account, existing content, and earnings history.

Account Suspension

Temporary suspension of full account access. Duration ranges from 24 hours to 90 days depending on severity and prior violation history. The creator is notified of the duration and reason. Suspension periods do not affect prior earnings already processed or pending scheduled payouts that pre-date the suspension, subject to any applicable payout hold.

Account Termination

Permanent and irrevocable closure of the account. All content is removed. The account holder is permanently banned from registering a new account. All pending payouts may be held pending fraud review and returned to paying fans as required by law or platform policy. Account termination is reserved for the most serious violations and for third or subsequent serious repeat violations.

Financial Hold

In cases involving suspected fraud, financial manipulation, regulatory requirement, or policy violations that affect financial transactions, the platform may place a hold on creator earnings pending investigation. Affected creators are notified of the hold and its basis.

Law Enforcement Referral

The platform refers matters to law enforcement in all cases involving CSAM, NCII, trafficking, credible threats of violence, terrorism, fraud, and identity theft. Referral occurs regardless of whether the account is still active at the time, and referral is not contingent on a successful appeal outcome.

Escalation by Violation Category

  • CSAM or NCII: immediate removal, evidence preservation, law enforcement referral, permanent account termination
  • Trafficking or forced exploitation content: immediate suspension, investigation, law enforcement referral, permanent termination
  • Terrorism propaganda: immediate removal, law enforcement notification, permanent ban
  • Credible violence threat: immediate account suspension, safety referral, investigation
  • Severe hate speech (Criminal Code threshold): immediate removal, police referral, suspension or termination based on prior history
  • Moderate hate speech: content removal, warning, suspension on repeat
  • Copyright (first valid DMCA notice): content removal, creator notification
  • Copyright (third valid DMCA within 12 months): permanent account termination under repeat infringer policy
  • Spam or metric manipulation: feature restriction, account suspension, termination on repeat
  • Minor first-time violation: warning, content review
Enforcement

17.Appeals and Dispute Resolution

Every user subject to a content removal, content restriction, feature restriction, account suspension, or account termination has the right to appeal. The appeals process is independent of the original enforcement decision, and appeals are reviewed by a Trust and Safety team member who was not involved in the original determination.

How to Submit an Appeal

  • Dashboard: Navigate to your Account, then Policy Alerts, then Appeal; submit from within the enforcement notification
  • Email: Contact safety@sgsuperfans.com with the subject line "Enforcement Appeal," your account username, and the content identifier or enforcement action reference number

Review Timelines

  • Standard appeal: reviewed within 7 business days of receipt of a complete appeal submission
  • Urgent content removal appeal: reviewed within 72 hours; request urgent review by marking the email subject line with "Urgent Appeal"; available for content removal decisions only

Second-Level Review

If a user contests the initial appeal decision, they may request a second-level review by a Trust and Safety leadership officer. Requests for second-level review must be submitted within 14 days of the first appeal decision. Second-level review is available once per enforcement incident.

Independent Review Panel

For disputes involving CSAM or NCII allegations against a creator where significant account rights are at stake and the creator denies the underlying allegation, SGSuperFans will convene an independent review panel comprising a Trust and Safety officer, legal counsel, and, where appropriate, an external advisor. The panel's recommendation is binding on the platform's operational response.

Finality and Legal Remedies

Enforcement decisions that have been reviewed through the full appeals process represent the platform's final operational determination. Users retain all legal rights and remedies available to them in a court of competent jurisdiction independently of the platform's process. Disputes arising from platform enforcement decisions are governed by the laws of Ontario, Canada, and the parties submit to the non-exclusive jurisdiction of the courts of Ontario.

Good Faith Protection

Appeals made in good faith do not expose the appellant to additional penalties regardless of outcome. Using the appeals process to harass Trust and Safety team members, submit frivolous repeated appeals after a full review, or delay enforcement of a clearly valid termination is itself a violation of platform policy.

No retaliation will be taken against any user for filing an appeal or for reporting policy violations in good faith. Reports and appeals are handled confidentially to the extent permitted by law and platform operations.
Contact

18.Reporting and Contact Channels

Users who encounter content that they believe violates this policy are strongly encouraged to report it. Prompt reporting enables our Trust and Safety team to review and act on violations quickly, protecting the user community as a whole.

In-Platform Reporting

Every post, story, reel, message thread, profile, and comment includes a Report function. Select the report category that most accurately describes the violation. Available categories include: child safety or CSAM; non-consensual intimate imagery; human trafficking or exploitation; hate speech; harassment or threats; violence or graphic content; spam or fraud; impersonation; copyright infringement; and other policy violation.

Email Contacts

Targeted Response Times

  • CSAM and NCII reports: initial action within 2 hours; full resolution within 24 hours
  • Trafficking, child safety, and credible violence threats: within 4 hours
  • All other reported violations: within 48 hours
  • Standard enforcement appeals: within 7 business days
  • Urgent content removal appeals: within 72 hours

External Reporting Resources

  • NCMEC CyberTipline (US): Report CSAM at missingkids.org/gethelpnow/cybertipline
  • Canadian Centre for Child Protection: Report CSAM at cybertip.ca
  • StopNCII.org: Proactively block intimate images at stopncii.org
  • Cyber Civil Rights Initiative: NCII survivor support at cybercivilrights.org
  • Imminent threats: Always call 911 or your local emergency number for immediate threats to physical safety; do not wait for platform review

Non-Retaliation Commitment

SGSuperFans commits to no retaliation against any user for making a good-faith report under this policy. A creator subject to a report does not gain any enforcement advantage against the reporting party solely on the basis of that report. Reporting is confidential to the extent permitted by operational necessity and applicable law. False reports made in bad faith are themselves a policy violation and may result in enforcement action against the reporting party.

This policy was reviewed and approved by the Trust and Safety team, legal counsel, and senior leadership of SGSuperFans Inc. For questions about the application of this policy, contact safety@sgsuperfans.com.