Content Monitoring Policy

Content Monitoring Policy

XYRA MEDIA LIMITED Content Monitoring Policy

1. Users of our website (“PrettyFans”), Web sites and online services may not submit or upload content that is unlawful, infringes copyright, or may reasonably be considered to be harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another's privacy, bigoted, hateful, or racially, ethnically or otherwise offensive or objectionable.

2. XYRA MEDIA Limited (“XYRA MEDIA”) has the right but not the obligation to monitor, screen, block, post, remove, modify, store and review such content or communications sent through PrettyFans, at any time and for any reason, including to ensure that the user generated content or communications conform to the Terms of Use, without prior notice to the user.

3. Every person who appears on any broadcast on PrettyFans must have their identity and age verified in order to ensure that all persons depicted are consenting adults. We may require that new users submit government issued photo identification, a signed compliance form or any other related information to confirm the users identity and age.

4. A verification of the user’s identity and age must be performed by XYRA MEDIA before granting a new User Account.

5. XYRA MEDIA may maintain a list of prohibited words used to identify illegal content including content related to child pornography, sex trafficking, human trafficking, prostitution, the depiction of non-consensual activity or sexual exploitation. The list of prohibited words shall be reviewed at our sole discretion in order to ensure compliance with applicable law.

6. It is expressly prohibited for users of PrettyFans to use the platform to arrange live in-person meetings with subscribers.

7. XYRA MEDIA’s internal billing system may block payments to and from individuals, entities and countries that appear on our blocked list.

8. Xyra shall carry out age verification or age estimation to identify who is or is not a child user.

9. Xyra shall carry out a suitable and sufficient content risk assessment(s) at regular six month intervals and take appropriate steps to keep such content risk assessment(s) remain up to date.

10. Xyra will provide access to PrettyFans based on the following principles:

a. Safety First – users or resources will not be granted access to Xyra systems and services until they have completed an age verification exercise.

b. Need to know – users or resources will be granted access to systems that are in accordance with their access privileges and authorisations.

c. Where possible, Xyra will set user accounts to automatically expire at a pre-set date. More specifically,

11. User accounts may be disabled after 3 months of inactivity.

12. Access Privileges will be disabled or removed when IT receives notification that a user is not compliant with the terms and conditions of this framework or has obtained a user account by illegitimate means.

13. Existing user accounts and access rights will be reviewed at least annually to detect dormant accounts and accounts with excessive privileges.

14. Xyra will also proactively offer adult users optional tools, at the first opportunity, to help them reduce the likelihood that they will encounter certain types of content.

15. Xyra shall establish processes to prevent children of all ages from encountering content that encourages, promotes or provides instruction for suicide and self-harm.

16. Xyra shall establish effective reporting and redress mechanisms in place enabling users to raise concerns about the safety of the platform and services.

17. Xyra shall remove harmful material within twenty-four hours of having become aware of such harmful material.

18. Xyra shall monitor the content on its channels and where necessary remove or take down content which poses a significant risk of causing harm to children.

19. Xyra shall put measures in place to prevent non-verified users from interacting with content which other users generate, upload or share on the service.

20. All users must use a unique password to access Xyra services, systems and applications.

21. Alternative authentication mechanisms that do not rely on a unique ID and password must be formally approved.

22. Upon receipt of a notice of claimed copyright infringement from a complaining party (the Complainant):

a. The designated agent or other member of the XYRA MEDIA team receiving the notice or message, in consultation with the legal department, shall (i) remove or disable access to the material that is alleged to be infringing; (ii) forward the written notice to any person who provided the allegedly infringing content, along with the contact information of the Complainant; and (iii) take reasonable steps to promptly notify the person who provided the allegedly infringing content, if known and if contact information is available, that XYRA MEDIA has or will promptly disable access to the allegedly infringing material and that the person may respond with a counter notification. In consultation with the legal department, XYRA MEDIA, may terminate the person’s online account in the case of repeat allegations of copyright infringement.

b. The notice to the person alleged to have infringed a copyright shall inform that person that if he or she believes that a notice of copyright infringement has been improperly submitted against him or her by a Complainant, that person may submit a counter notification. The notice to the person alleged to have infringed a copyright can advise that to be effective, a counter notification must be a written communication containing (i) the person’s physical or electronic signature; (ii) identification of the material removed or to which access has been disabled; (iii) a statement under penalty of perjury that you have a good faith belief that removal or disablement of the material was a mistake or that the material was misidentified; and (iv) the person’s name, address, and telephone number.

23. Upon receipt of any report of abusive or unlawful content (not involving a notice of claimed copyright infringement) or upon otherwise independently learning or becoming aware of such content:

a. The member of the XYRA MEDIA team will investigate the matter and will consult within the team and/or external legal counsel as needed to determine whether to remove or otherwise modify the content.

b. If the content appears facially to the XYRA MEDIA team member investigating the matter to be unlawful or otherwise abusive or inconsistent with the Terms of Use, the Team member shall take all appropriate steps to have the content promptly removed from the Website.

c. If the content does not facially violate the Terms of Use, the XYRA MEDIA Team member must consult within the team. The content will remain on the Website unaltered unless an executive, or their designee, determines that the content should be removed or modified.

Last updated: September 2025