COMPLIANCE AND CONTENT MODERATION POLICY — LIBERTY FANS
Platform: Liberty Fans Responsible company: LIBERDADE DIGITAL TECNOLOGIA E MARKETING LTDA - EPP CNPJ (Brazilian company registration number): 57.984.763/0001-31 Responsible department: Compliance Department Approving body: Compliance Board Contact, reporting and review channel: contato@libertyfans.com.br Version: 1.0 Effective date: Upon approval by the Compliance Board Review frequency: Every six months
1. Purpose
This Policy establishes Liberty Fans guidelines for preventing, identifying and addressing content and conduct involving the sexual abuse or exploitation of children and adolescents, coercion, sexual exploitation, human trafficking, intimate content shared without consent and other activities contrary to Brazilian law. Its application aims to protect the people involved, prevent the platform from being used for unlawful practices and establish procedures for reporting, assessment, content removal, account suspension or closure and notification of the competent authorities.
2. Scope and responsibility
This Policy applies to users, subscribers, content creators, partners and anyone else who uses Liberty Fans. It covers photos, videos, live streams, private messages, comments, profiles, offers and content sales, as well as other interactions conducted through the platform. The Compliance Department is responsible for applying this Policy and handling reports. The Compliance Board is responsible for its approval and oversight.
3. Age restriction and verification
Liberty Fans is intended exclusively for people aged 18 or older. People under 18 are prohibited from participating as users, creators or participants in sexual content made available on the platform. Identity, age and relevant documentation are verified through KYC procedures — user identification and verification — and document review. Where there is significant doubt about the identity or age of a person involved, the platform may restrict the account or content as a precaution until verification is complete. Insufficient documentation will prevent the activity or content under review from being authorized.
4. Prohibited content and conduct
Using Liberty Fans to produce, publish, transmit, sell, request, promote or facilitate the following is prohibited: a) Content depicting sexual abuse or exploitation involving children or adolescents, including manipulated or artificially generated material; b) Grooming children or adolescents for sexual purposes; c) Sexual acts or content production involving violence, threats, fraud, blackmail, coercion or exploitation of vulnerability; d) Sexual exploitation or human trafficking, including recruitment, brokering or trade connected to these practices; e) Disclosure, sale or redistribution of intimate content without authorization from the people depicted; f) Intimate recordings obtained without consent, unauthorized sexual montages or threats of disclosure; g) Document forgery, misuse of another person's identity or submission of false information to circumvent verification; h) Reposting content removed for violating this Policy or using other accounts to circumvent measures imposed; i) Other content or conduct contrary to Brazilian law. A claim of consent does not make content depicting sexual abuse or exploitation involving people under 18 admissible.
5. Consent and documentation
Everyone depicted in intimate content must be aged 18 or older and must have consented to their participation and to the disclosure or sale carried out. Consent to a sexual relationship or to recording content does not, by itself, authorize its publication, sale or redistribution. Liberty Fans uses KYC and document review to verify identity, age and relevant authorization documentation. Identity verification does not replace proof of consent. The person responsible for publishing must, upon request, provide sufficient documentation for the people depicted and the corresponding authorizations. Anyone who identifies intimate content shared without their authorization may request review and removal by emailing contato@libertyfans.com.br. Where there are significant indications of a lack of consent, the content may be blocked as a precaution during the investigation.
6. Prevention and automated moderation
Liberty Fans uses automated moderation to identify content and behavior potentially incompatible with this Policy. Alerts generated by automated moderation and reports received will be forwarded to the Compliance Department for assessment and appropriate action. Moderation may result in precautionary restrictions on content or accounts, requests for documentation, content removal and account suspension or closure. Checks will be conducted in accordance with applicable law, personal data protection and information confidentiality.
7. Reporting channel
Reports and content removal requests must be sent to: contato@libertyfans.com.br The channel may be used by users, people depicted in content, representatives, authorities and third parties who identify a possible violation. Whenever possible, reports should include: a) A link, profile identification or content location; b) A description of the situation and the reason for the report; c) The date or other information that helps identify the content; d) Contact details for a response. Reporters will not be required to download, store or forward material depicting the sexual abuse of children or adolescents. Links, identifiers and descriptive information should be prioritized to locate the content. Reports will be handled confidentially, with access restricted to those responsible for investigating and fulfilling legal obligations. The platform does not tolerate retaliation against reports made in good faith.
8. Content review and removal — takedown
Reports and moderation alerts will be handled through the following steps: a) Registration: identification of the incident, date received and available information; b) Triage: assessment of severity, urgency and risks to the people involved; c) Preventive measures: blocking or restricting content or accounts where there are significant indications of a violation; d) Investigation: review of available information and, when necessary, requests for documentation or clarification; e) Decision: content removal, continuation or lifting of restrictions, account measures or closure of the incident with stated grounds; f) Communication and recordkeeping: documentation of actions and responses to the reporter or affected people, whenever possible and with due regard for privacy and confidentiality. The operational deadline for triage, an initial response and a decision, including removal where appropriate, will be up to 3 business days from receipt of the report or identification of the incident. When a conclusion depends on additional information or external action, the Compliance Department will provide an update on progress and measures taken within that deadline, maintaining any necessary precautionary restrictions. Cases involving suspected sexual abuse or exploitation of minors, coercion, human trafficking or immediate risk will be prioritized and may receive immediate action. The 3-business-day deadline does not authorize delaying urgent action or replace deadlines set by law or authorities. Making content unavailable to the public will be handled separately from any legal preservation of records and evidence.
9. Account suspension and closure
Content or conduct contrary to Brazilian law may result in content removal, feature restrictions, precautionary suspension or permanent account closure. The measure imposed will consider: a) The severity of the conduct and risk to the people involved; b) Indications of participation in or facilitation of unlawful practices; c) Repeated violations; d) Document forgery or concealment of information; e) Reposting removed material or attempting to circumvent restrictions. Where there are significant indications of unlawful activity, the account may be suspended as a precaution during the investigation. If a serious violation is confirmed, permanent closure may occur on the first incident, without prior warning. Precautionary suspension will remain in place for as long as necessary to investigate or protect the people involved, subject to reassessment by the Compliance Department. The account holder will be informed of the measure and its grounds when that communication does not compromise victim protection, the investigation or a confidentiality obligation.
10. Review of decisions
The account holder or affected person may request review of a decision by emailing contato@libertyfans.com.br, identifying the account or content involved, the reasons for the request and relevant information. The Compliance Department will assess the request and provide a response within 3 business days of receipt, taking into account the need for additional information. A review request does not automatically reinstate content or an account. Restrictions may remain in place while there is a risk or pending verification.
11. Notification of authorities
LIBERDADE DIGITAL TECNOLOGIA E MARKETING LTDA - EPP, through its representatives and Compliance Department, will be responsible for assessing situations with indications of criminal activity and notifying the competent authorities. Notification will take into account applicable legal obligations, the severity of the incident and the need to protect the people involved. Situations of immediate risk will be referred as a priority, without waiting for the internal investigation to conclude. The company will cooperate with legally valid requests from authorities and court orders, preserving and providing the relevant records. Information will be shared through secure means, limited to what is necessary and documented with identification of the recipient authority, the grounds and the information provided.
12. Data protection and record preservation
Records of reports, assessments, decisions and actions will be stored on the company's own server, with access restricted to authorized people. Processing of this information will comply with applicable Brazilian law, including personal data protection rules. Records will be retained for as long as necessary for investigation, fulfillment of legal obligations and the lawful exercise of rights, subject to any preservation orders. Evidence will be preserved in a controlled and legally appropriate manner, avoiding unnecessary reproduction, circulation or access to unlawful content. Storage on the company's own server does not remove the need for security measures, access controls and protection against misuse.
13. Governance and periodic review
The Compliance Department will maintain incident records and monitor compliance with the procedures established in this Policy, including response deadlines, repeated violations and measures imposed. This Policy will be reviewed every six months, under the supervision of the Compliance Board, and whenever changes in law, changes in features or significant incidents require an update. The current version must be made available for users to consult.
14. Effective date
This Policy takes effect upon approval by the Compliance Board of LIBERDADE DIGITAL TECNOLOGIA E MARKETING LTDA - EPP and forms part of the rules for using Liberty Fans. LIBERDADE DIGITAL TECNOLOGIA E MARKETING LTDA - EPP CNPJ: 57.984.763/0001-31 Liberty Fans — Compliance Board Contact: contato@libertyfans.com.br