Content Moderation

What is our policy:

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

How we enforce our policy:

1. Text Moderation with Machine Learning:

SLUSHY sets forth a list of terms that are forbidden from use on the Platform in any manner whatsoever including captions, display names, handles, direct messages, biographies, hashtags, and search terms (“Forbidden Terms”). SLUSHY 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.

SLUSHY also uses Hive’s (https://hivemoderation.com/) machine learning API to automatically scan, identify, and flag cyberbullying, harassment, predatory behaviour, self-harm,  and CSAM. These tools can detect all attempts to circumvent text moderation with alternative spellings or special characters. If Forbidden Terms are detected by or reported to SLUSHY then the Content is removed immediately from the Platform. Violators' accounts are suspended until further review, which may result in account termination and permanent banning.

2. Child Sexual Abuse Material (CSAM) Identification, Removal and Reporting with Hash Matching:

SLUSHY screens all content against Safer’s (a registered 501(C)(3) organization - https://safer.io/) CSAM Hash List of over 10 million hashes from ESP, NGO, and SE lists.

SLUSHY leverages Safer’s image and video Hash Matching service to generate cryptographic and perceptual hashes for the detection and identification of known and reported CSAM. If Safer matches or identifies CSAM then it is blocked from being published on the Platform. Safer's Reporting API enables programmatic reporting of detected CSAM to NCMEC’s CyberTipline and connects to secure storage to manage preservation requirements. All relevant information is shared with the appropriate law-enforcement agencies. Any personal information and content uploaded by a User that has or is suspected to have violated any law related to child pornography or the exploitation of minors. Violators' accounts are terminated immediately.

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

SLUSHY screens all Content through Amazon Rekogniton’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
    1. Nazi Party
    2. White Supremacy
    3. 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.

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

SLUSHY utilizes a third-party human-in-the-loop service provider with over 700+ trained experts to manually review (based on SLUSHY’s Acceptable Use Policy) any flagged Content from the Automated Content Moderation process. These experts adhere to strict security guidelines and operate from a SOC 2 Type1 compliant delivery center (paperless and supervised environment with no access to USBs or smart phones, entrances to production areas are restricted via Biometric Access, and they are under 24x7-camera surveillance). 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 SLUSHY.

In addition to pre-publication review of static Content, SLUSHY applies real-time monitoring to Live Content. Automated systems and trained human moderators actively monitor live streams for violations of the Acceptable Use Policy. Upon detection of prohibited content or behavior, SLUSHY may immediately terminate the stream, remove participants, or take other enforcement actions without prior notice to the Creator. All live streaming moderation actions are logged and subject to the same review and appeal processes outlined in this Policy and the Content Removal Policy.

How to submit an Appeal of Content Removal:

Email

1. Any person can submit an “Appeal of Content Removal” by emailing SLUSHY at support@slushy.com.
2. You will need to include your full legal name, mailing address, phone number, and the post ID for the Content that was removed, which will be written in the email you received notifying you of your Content’s removal.

Mail

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

Boink Technologies Inc.

2045 Biscayne Blvd. Suite 118

Miami, FL 33137

1. You will need to include your full legal name, mailing address, phone number, and the post ID for the Content that was removed, which will be written in the email you received notifying you of your Content’s removal

How we resolve your Appeal for Content 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 Publish the Content, 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 post will remain removed.