Privacy

1. Purpose

CP Productions Inc. (hereafter referred to as CPP) has created this Privacy Policy to demonstrate our dedication to respecting privacy. This Privacy Policy sets out our practices with respect to personal information collected regarding visitors and subscribers (collectively referred as 'you') of this Site. This Site is an adult website and membership is solely restricted to adults; persons under the age of eighteen are strictly prohibited from this Site and we do not intentionally collect information on individuals under the age of eighteen. By visiting or subscribing to this Site, you agree and consent to the terms of this Privacy Policy as amended from time to time, as well as the terms and conditions of this Site.

2. Non-Personal Information and Cookies

Certain non-personal information may be collected from visitors to this Site including, but not limited to, their browser type, operating system, IP address, and the domain name from which they accessed the Site. Other non-personal information may be collected such as browsing behavior, date and time of visit, the pages visited; the time spent viewing the Site, the number of times the visitor returns to the Site, and click-stream data. We do not track any information about visitors once they leave our Site. We may use cookies to collect this information. We may also allow unaffiliated third parties, such as advertisers, to serve cookies to visitors of our Site. You are always free to decline cookies, but in doing so they may not be able to use certain features on our Site.

3. Use of Information

We collect personal information so that we may custom tailor the web experience for each subscriber and offer the best products and services to meet the needs of each subscriber.

We may use information collected from visitors to our Site for any of the following purposes:

1) to send visitors information and promotional materials about our company, which will not continue if opted out of,

2) to send visitors information and promotional materials from our marketing partners and third parties,

3) to deliver targeted display advertisements and offers by email, which will not continue if opted out of,

4) to contact visitors to our Site when necessary,

5) to allow one-click purchases or access to proprietary content by pre-populating fields, within registration or other transaction screens, with a visitor's name, billing address, all as provided by that visitor,

6) to help diagnose problems with our server,

7) to administer our Site,

8) to conduct internal reviews of our Site (e.g., to determine the number of visitors to the Site),

9) to help us better understand visitors' use of our Site, and

10) to protect the security or integrity of our Site.

Since part of the personal information that is collected and safeguarded by us is your email address, we try very hard to respect your time and privacy by controlling and limiting the frequency of mailings. If you receive a mailing from us or one of our marketing partners, it is because your email address is either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future, or you have registered or purchased or otherwise have an existing relationship with us.

There may be occasions when you will be presented with special offers either from us or from third-party service or content providers, which may include communications, newsletters, commercial advertising, or other promotional or special event materials (collectively referred to as 'Offers'). Your consent to this Privacy Policy acts as your consent to receive these occasional mailings by us and by our third party service or content providers.

The Site is not responsible or liable for the use of any information that a subscriber may provide, or that is gathered by third-party websites that have ads or links on the Site. This Site does not control, monitor or endorse the information gathering practices or Privacy Policies of any of those third-party websites. Whenever applicable, each subscriber should seek to read the Privacy Policy of any third-party website provider that has an advertising banner, advertises or has a link on the Site.

If you have received unsolicited email sent via this system or purporting to be sent via this system, please forward a copy of that email with your comments to support@real4cash.com

4. Security

This Site has security measures in place to protect the loss, misuse and alteration of the information under our control. As for all other information, visitors and subscribers should consider this communication and information to be non-confidential, and consequently, we assume no responsibility or liability if any information relating to any visitor or subscriber is intercepted and/or used by an unintended recipient.

5. Acceptance of these Terms

By visiting or subscribing to this Site, you agree to the practices described in this Privacy Policy. We may at any time revise or amend any of these terms and conditions. You are bound by any such revisions and should therefore periodically visit this page to review the then-current terms and conditions to which you are bound. To the extent that any of the third-party sites accessible through our Site (such as our advertisers) have different privacy practices from those stated in this Privacy Policy, those third-party privacy practices govern the collection and use of information you provide when visiting those sites. We are not responsible for the policies, content, and practices of other companies which may collect personal information as a third-party web service provider that has an advertising banner or link on the Site.

Content Moderation

1. Purpose

CPP is committed to producing, distributing, and managing adult content in a lawful, ethical, and responsible manner.

This Adult Content Moderation Policy establishes the standards and procedures CPP uses to review, approve, restrict, remove, and respond to adult content.

The primary objectives of this Policy are to:

1. -Protect performers, employees, customers, and other individuals;
2. -Prevent the exploitation of minors;
3. -Ensure that individuals appearing in content are adults;
4. -Ensure that appropriate consent has been obtained;
5. -Prevent non-consensual or unlawfully distributed content;
6. -Comply with applicable laws and contractual requirements;
7. -Protect personal and confidential information; and
8. -Maintain consistent and accountable content-moderation practices.

2. Scope

This Policy applies to adult content created, acquired, licensed, published, distributed, or otherwise managed by CPP.

It applies to:

1. -Employees and contractors;
2. -Performers and creators;
3. -Producers and production personnel;
4. -Content reviewers and moderators;
5. -Uploaders and licensors;
6. -Third-party production partners;
7. -Distributors and service providers; and
8. -Other parties acting on behalf of CPP.

The Policy applies to photographs, videos, livestreams, audio, written material, advertisements, promotional materials, thumbnails, metadata, descriptions, comments, and other associated content.

3. Fundamental Requirements

CPP will not knowingly publish or distribute adult content unless it has a reasonable basis to establish that:

1. -Every person depicted was 18 years of age or older at the time the content was created;
2. -The identity and age of each person depicted have been appropriately verified;
3. -Each person depicted provided appropriate, informed, and voluntary consent to participate;
4. -CPP has the necessary rights or authorization to publish and distribute the content;
5. -The content does not otherwise violate this Policy or applicable law; and
6. -Required records and documentation have been completed and maintained.

Where required documentation is missing, incomplete, inconsistent, or cannot be reasonably verified, the content must not be published until the issue has been resolved.

4. Age and Identity Verification

CPP maintains procedures designed to verify the identity and age of every person appearing in covered adult content.

Verification may include:

1. -Government-issued identification;
2. -Identity verification procedures;
3. -Date-of-birth verification;
4. -Performer records and releases;
5. -Production records; and
6. -Other appropriate documentation required by applicable law.

A declaration that a person is an adult is not, by itself, sufficient where formal verification or records are required.

Verification information must be handled securely and access must be limited to authorized personnel.

5. Consent Requirements

All persons appearing in adult content must provide appropriate consent to participate.

Consent should be:

1. -Voluntary;
2. -Informed;
3. -Specific to the relevant activity and intended use;
4. -Obtained without coercion, threats, or undue pressure; and
5. -Documented in accordance with CPP contractual and record-keeping requirements.

Where appropriate, releases or performer agreements should identify the permitted uses, distribution rights, and other relevant conditions.

CPP will not knowingly publish content where there is credible evidence that a person did not consent to the creation or distribution of the material.

6. Prohibited Content

CPP prohibits the creation, acquisition, publication, distribution, or promotion of content involving the following.

6.1 Minors

Any sexual content involving a person under 18 is strictly prohibited.

CPP will not knowingly accept, publish, possess for distribution, or facilitate the distribution of sexual content involving minors.

Content must also be rejected where the required evidence of adulthood cannot be established.

Suspected child sexual abuse material must be immediately escalated through CPP designated legal and safety procedures.

Personnel must not unnecessarily copy, download, forward, or distribute suspected illegal material.

6.2 Non-Consensual Sexual Content

CPP prohibits content depicting a person in sexual or intimate circumstances where the person did not consent to:

1. -The creation of the material;
2. -The recording or photographing of the material; or
3. -The publication or distribution of the material.

This includes unlawfully distributed intimate imagery and other forms of non-consensual sexual content.

6.3 Coercion and Exploitation

Content involving coercion, trafficking, forced labor, sexual exploitation, or other forms of exploitation is prohibited.

Potential indicators of coercion or exploitation must be escalated for additional review.

6.4 Incestuous or Sexualized Minor Themes

Content that sexualizes minors or presents individuals as minors in a sexual context is prohibited.

This includes titles, descriptions, tags, promotional materials, costumes, or other presentation that intentionally sexualizes underage persons or is designed to evade the prohibition on sexual content involving minors.

6.5 Violence and Abuse

Content involving actual sexual assault, abuse, or non-consensual violence is prohibited.

Content involving consensual adult activities must nevertheless comply with applicable law, contractual requirements, and CPP other safety standards.

6.6 Illegal Content

CPP prohibits content that violates applicable criminal or other laws.

Where the legal status of content is unclear, the content should be escalated to the designated Compliance or Legal function before publication.

7. Content Review Process

Before publication, content should undergo an appropriate review based on its risk and distribution channel.

The review process may include:

Step 1 — Submission

Content is submitted with required performer, rights, and production documentation.

Step 2 — Documentation Review

Authorized personnel verify that required age, identity, consent, rights, and other records are present.

Step 3 — Content Review

The content is reviewed for violations of this Policy, including prohibited persons, non-consensual material, exploitation, illegal activity, and other safety concerns.

Step 4 — Decision

Content is classified as:

1. -Approved — eligible for publication;
2. -Restricted — permitted only with specified restrictions;
3. -Pending Review — additional information or investigation is required; or
4. -Rejected — prohibited or insufficiently documented.

Step 5 — Record Keeping

Material moderation decisions and required supporting records are documented and maintained in accordance with CPP retention requirements.

8. Automated and Human Moderation

Where appropriate, CPP may use automated technologies to assist with:

1. -Content classification;
2. -Duplicate-content detection;
3. -Detection of potentially prohibited material;
4. -Fraud or account-abuse detection;
5. -Metadata analysis; and
6. -Identification of content requiring human review.

Automated systems should be treated as screening and risk-management tools rather than the sole basis for decisions in sensitive or high-risk cases.

Human review should be used for significant enforcement decisions, appeals, ambiguous cases, and high-risk content.

9. User and Performer Reporting

CPP will maintain an appropriate mechanism for reporting potentially prohibited or non-consensual content.

Reports may be submitted by:

1. -Performers;
2. -Customers;
3. -Employees;
4. -Rights holders;
5. -Content partners;
6. -Law-enforcement authorities; or
7. -Other individuals with a legitimate concern.

Reports should include sufficient information to identify the relevant content and explain the concern.

Reporting Contact: support@real4cash.com

10. Urgent Takedown Procedure

Reports involving suspected minors, non-consensual intimate content, trafficking, exploitation, credible threats, or other serious safety concerns should receive priority handling.

Depending on the circumstances, CPP may:

1. -Temporarily restrict access to the content;
2. -Prevent further distribution;
3. -Preserve relevant records in accordance with legal requirements;
4. -Investigate the report;
5. -Contact the affected performer or rights holder where appropriate;
6. -Escalate the matter to Legal or Compliance;
7. -Terminate or restrict accounts or business relationships; and
8. -Notify appropriate authorities where legally required or appropriate.

The goal of an urgent takedown is to reduce continuing harm while allowing the matter to be appropriately investigated.

11. Non-Consensual Content Complaints

Individuals who believe their image or likeness has been distributed without authorization may submit a complaint through the designated reporting channel.

CPP will evaluate the complaint promptly and may temporarily restrict the disputed content while investigating.

Where CPP determines that content was published without appropriate authorization or consent, it may remove the content and take additional appropriate action.

12. Performer Protection

CPP recognizes that performers may face heightened privacy and safety risks.

Accordingly, CPP will seek to:

1. -Protect performer identity and personal information;
2. -Limit access to sensitive records;
3. -Maintain appropriate consent and release documentation;
4. -Provide appropriate reporting channels;
5. -Respond to credible safety concerns;
6. -Prevent unauthorized redistribution where reasonably possible; and
7. -Investigate credible allegations of coercion or non-consensual distribution.

Retaliation against a person who raises a good-faith safety or consent concern is prohibited.

13. Privacy and Security

Personal information collected for age verification, identity verification, consent documentation, payment, contracts, or moderation must be handled securely.

Access should be limited to personnel with a legitimate business need.

CPP should collect and retain only information reasonably necessary for legitimate legal, compliance, business, and operational purposes.

Where third-party verification or moderation providers are used, CPP should conduct appropriate vendor due diligence and establish suitable confidentiality and security requirements.

Current guidance from the FTC emphasizes limiting age-verification information to the age-verification purpose, retaining it only as long as necessary, and applying reasonable security safeguards.

14. Record Keeping

CPP will maintain appropriate records relating to adult content and its moderation processes.

Depending on applicable legal requirements, records may include:

1. -Performer identity and age verification;
2. -Consent documentation;
3. -Performer releases and agreements;
4. -Production information;
5. -Content ownership or licensing information;
6. -Moderation decisions;
7. -Takedown requests;
8. -Appeals;
9. -Investigations;
10. -Enforcement actions; and
11. -Reports to authorities.

Records must be maintained securely and for the period required by applicable law and CPP retention schedule.

15. Copyright and Unauthorized Distribution

CPP respects applicable intellectual-property rights.

Content may be restricted or removed when there is credible evidence of:

1. -Unauthorized copying;
2. -Unauthorized redistribution;
3. -Copyright infringement;
4. -Misappropriation of content; or
5. -Unauthorized use of a performer's likeness.

Rights-holder complaints should be directed to:

Copyright / Rights Contact: support@real4cash.com

16. Appeals

Where appropriate, an individual affected by a moderation decision may request a review.

An appeal should identify:

1. -The content or account involved;
2. -The decision being challenged;
3. -The reason the decision should be reconsidered; and
4. -Any relevant supporting information.

CPP may maintain restrictions during an appeal where there is a significant safety, legal, privacy, or consent concern.

17. Enforcement

Violations of this Policy may result in:

1. -Content removal;
2. -Content restrictions;
3. -Account suspension;
4. -Account termination;
5. -Termination of a supplier or creator relationship;
6. -Loss of publishing privileges;
7. -Contractual remedies; and/or
8. -Referral to appropriate authorities.

The severity of the response will depend on the nature and circumstances of the violation.

18. Law-Enforcement and Regulatory Requests

CPP will respond appropriately to valid legal requests and cooperate with law-enforcement or regulatory authorities where required by applicable law.

Requests involving suspected criminal activity, minors, exploitation, subpoenas, warrants, or other significant legal matters should be promptly referred to the designated Legal or Compliance representative.

19. Training

Personnel responsible for content review, production, compliance, customer support, or safety should receive appropriate training.

Training may cover:

1. -Age and identity verification;
2. -Consent requirements;
3. -Recognizing non-consensual content;
4. -Prohibited content;
5. -Privacy and information security;
6. -Reporting and escalation;
7. -Evidence preservation;
8. -Performer safety; and
9. -Appropriate handling of sensitive material.

20. Monitoring and Auditing

CPP may periodically review its moderation program to assess effectiveness.

Reviews may include:

1. -Sample content audits;
2. -Documentation audits;
3. -Age and identity verification checks;
4. -Consent-record reviews;
5. -Takedown response times;
6. -Appeals and complaint outcomes;
7. -Third-party vendor reviews; and
8. -Policy and procedure testing.

Identified deficiencies should be documented and addressed through appropriate corrective action.

21. Responsibility

Operational responsibilities may be assigned to:

1. -Compliance;
2. -Legal;
3. -Content Moderation;
4. -Production Management;
5. -Information Security;
6. -Human Resources; and
7. -Customer Support.

Serious or high-risk matters must be escalated according to CPP incident-response procedures.

22. Policy Review

This Policy will be reviewed periodically and updated when necessary to reflect:

1. -Changes in applicable law;
2. -Regulatory developments;
3. -Industry standards;
4. -New technologies;
5. -Emerging safety risks;
6. -Changes to CPP services; and
7. -Lessons learned from incidents and investigations.

Content Safety Commitment

CPP is committed to responsible adult-content production and distribution. We require appropriate verification of adulthood, identity, consent, and content rights and maintain a zero-tolerance approach to content involving minors, exploitation, trafficking, or non-consensual sexual material.

We seek to protect performers and other individuals whose rights, privacy, safety, or dignity may be affected by content under our control and to respond promptly and appropriately when concerns are identified.

ID&V and Consent

1. Purpose

CPP is committed to ensuring that every individual appearing in adult content is an appropriately verified adult who has provided informed, voluntary, and documented consent.

This Adult Identification, Verification and Consent (“ID&V and Consent”) Procedure establishes the controls CPP uses to:

1. -Verify the identity and age of performers;
2. -Confirm that each performer is legally an adult before participation;
3. -Obtain appropriate informed and voluntary consent;
4. -Document performer authorization and content-use rights;
5. -Protect sensitive identity and consent records;
6. -Prevent the participation of minors;
7. -Prevent coercion, exploitation, and non-consensual content; and
8. -Maintain appropriate records for compliance and auditing purposes.

2. Scope

This Procedure applies to every individual who appears, or is intended to appear, in adult content produced, acquired, licensed, published, or distributed by CPP.

It applies to:

1. -Performers;
2. -Models;
3. -Actors;
4. -Producers appearing in content;
5. -Guest participants;
6. -Contractors or creators appearing in content; and
7. -Any other person whose image, likeness, voice, or identifiable participation is included in covered adult content.

The Procedure applies regardless of whether the content is produced by CPP, commissioned from a third party, acquired from an independent creator, or licensed from another party.

3. Core Principles

CPP follows these principles:

1. -No verification, no participation.
2. -Every performer must be verified as an adult before participating in adult-content production.
3. -Identity must be verified using reliable documentation or an approved verification process.
4. -Consent must be voluntary, informed, and appropriately documented.
5. -Consent may be withdrawn or challenged, subject to applicable contractual and legal rights.
6. -No individual may be pressured, threatened, deceived, or coerced into participating.
7. -Sensitive identification and consent records must be protected.
8. -Where required information is missing, inconsistent, expired, or unreliable, production must stop until the issue is resolved.
9. -Suspected minors, forged documentation, trafficking, coercion, or other serious concerns must be escalated immediately.

4. Roles and Responsibilities

4.1 Compliance / Authorized Verification Personnel

Responsible for:

1. -Reviewing verification documentation;
2. -Confirming age and identity;
3. -Maintaining verification records;
4. -Resolving discrepancies;
5. -Approving or rejecting performer eligibility; and
6. -Escalating suspected fraud, exploitation, or other serious concerns.

4.2 Production Management

Responsible for:

1. -Ensuring no unverified individual participates in production;
2. -Confirming required documentation has been approved before filming;
3. -Ensuring production conditions are consistent with documented consent; and
4. -Reporting concerns to Compliance.

4.3 Performers

Performers are responsible for:

1. -Providing accurate identification information;
2. -Providing truthful information regarding age and identity;
3. -Reviewing applicable consent and release documents;
4. -Providing informed consent before participating; and
5. -Raising concerns if participation, activities, or distribution differ from what was agreed.

4.4 Records Administrator

Where applicable, the Records Administrator is responsible for:

1. -Secure storage;
2. -Access controls;
3. -Record retention;
4. -Retrieval for legitimate compliance purposes; and
5. -Secure disposal when retention requirements have expired.

5. Pre-Production Verification

No person may participate in adult-content production until the required ID&V process has been completed.

Before production begins, CPP must establish:

1. -The person's legal identity;
2. -Their date of birth;
3. -That they are an adult;
4. -That the identity document belongs to the individual presenting it;
5. -That the documentation is sufficiently reliable for the applicable verification requirements; and
6. -That required consent and release documentation has been completed.

Production personnel must not rely solely on verbal statements of age.

6. Acceptable Identification

CPP will use an appropriate government-issued identity document or an approved identity-verification method.

Depending on the jurisdiction and circumstances, acceptable documentation may include:

1. -Passport;
2. -Driver's license;
3. -Government-issued identification card; or
4. -Other reliable government-issued identification.

Documents that are expired, altered, suspicious, illegible, or otherwise unreliable must not be accepted without additional verification.

CPP may use an approved third-party identity-verification provider where appropriate.

7. Identity Verification

Authorized personnel should compare the individual's identity against the submitted documentation and verify that the information is reasonably consistent.

The verification process may include:

1. -Reviewing the photograph;
2. -Comparing identifying information;
3. -Confirming date of birth;
4. -Checking document validity;
5. -Using an approved electronic verification service;
6. -Confirming the individual is physically present where required; and
7. -Conducting additional checks where discrepancies or risk indicators exist.

If identity cannot be reliably established, the individual must not participate until verification is successfully completed.

8. Age Verification

The individual must be verified as 18 years of age or older, or meet the applicable legal age requirement in the relevant jurisdiction, before participating in adult-content production.

Age verification must be completed before:

1. -Photography;
2. -Videography;
3. -Recording;
4. -Livestreaming;
5. -Rehearsal involving adult-content activities; or
6. -Any other covered production activity.

A person who cannot provide sufficient evidence of adulthood must not participate.

9. Verification Discrepancies

If information differs between documents, contracts, production records, or other sources, the discrepancy must be resolved before participation.

Examples include:

1. -Different dates of birth;
2. -Different legal names without supporting documentation;
3. -Inconsistent identification numbers;
4. -Suspicious or altered documents;
5. -Photographs that do not reasonably correspond to the individual; or
6. -Information suggesting that the person may not be an adult.

Where a discrepancy cannot be satisfactorily resolved, the individual must not participate.

Potential identity fraud or falsification should be escalated to Compliance and, where appropriate, Legal.

10. Consent Requirements

Every performer must provide informed and voluntary consent before participating.

Consent must be obtained without:

1. -Threats;
2. -Coercion;
3. -Intimidation;
4. -Deception about material aspects of the production;
5. -Unlawful pressure; or
6. -Exploitation of a person's vulnerability.

Consent must be sufficiently informed for the individual to understand the nature of their participation and the intended use of the resulting content.

11. Performer Release and Consent Documentation

Before production, each performer must complete the applicable release, consent form, contract, or equivalent documentation.

Documentation should identify, as appropriate:

1. -The performer's legal name;
2. -Stage or professional name, if applicable;
3. -Production or project name;
4. -Date of participation;
5. -Nature of the authorized content;
6. -Intended uses and distribution;
7. -Applicable rights and permissions;
8. -Compensation or other contractual terms;
9. -Signatures or legally valid electronic acceptance; and
10. -Any additional information required by applicable law.

12. Consent Must Match the Production

Production personnel must ensure that the actual content created is consistent with the scope of the performer's documented consent.

If the planned content materially changes, production should pause until appropriate additional consent is obtained.

Examples of material changes may include:

1. -Adding a new participant;
2. -Changing the nature or scope of the planned activity;
3. -Changing the intended distribution;
4. -Using content for a materially different commercial purpose; or
5. -Creating additional content outside the agreed scope.

A previously signed document should not automatically be treated as authorization for materially different activities.

13. Consent During Production

Consent is an ongoing requirement.

A performer may communicate discomfort, objections, or a desire to stop participating during production.

Production personnel must respond appropriately and must not use threats, intimidation, or improper pressure to compel continued participation.

If a performer withdraws consent during production, the production team must follow the applicable production-stop and escalation procedures.

14. Post-Production and Distribution Authorization

Before content is released, CPP should confirm that:

1. -Required identity and age verification has been completed;
2. -Required performer documentation is complete;
3. -Required consent and release documentation is available;
4. -The content falls within the authorized scope;
5. -Required rights or licenses have been obtained; and
6. -No unresolved complaint or safety issue prevents distribution.

Content must not be distributed where a material consent or verification issue remains unresolved.

15. Third-Party and Licensed Content

When CPP acquires or licenses adult content from a third party, the responsible party must provide appropriate assurances and documentation establishing that:

1. -Every person depicted was an adult;
2. -Identity and age verification requirements were satisfied;
3. -Appropriate consent and releases were obtained;
4. -The third party has the necessary rights to provide the content; and
5. -The content complies with applicable law and CPP' requirements.

CPP may conduct additional due diligence for higher-risk suppliers, creators, or content.

16. Privacy and Security

ID&V records can contain highly sensitive personal information.

CPP will implement appropriate safeguards designed to protect such information from unauthorized access, disclosure, alteration, or loss.

Controls may include:

1. -Restricted access;
2. -Secure electronic storage;
3. -Encryption where appropriate;
4. -Access logging;
5. -Strong authentication;
6. -Confidentiality obligations;
7. -Secure transmission; and
8. -Secure disposal.

Personnel must not store identity documents or sensitive verification information on personal devices or unauthorized storage services.

17. Access to Verification Records

Access to ID&V and consent records must be limited to authorized personnel with a legitimate business, legal, compliance, or operational need.

Production personnel should receive only the information necessary for them to perform their duties.

Where possible, sensitive identification information should not be unnecessarily shared with customers, other performers, contractors, or unrelated employees.

18. Retention

CPP will retain ID&V and consent records for the period required by applicable law, contractual obligations, legitimate business requirements, and the company's records-retention schedule.

When records are no longer required, they should be securely destroyed or deleted in accordance with applicable retention and privacy requirements.

19. Suspected Minor or Invalid Verification

If CPP receives information suggesting that an individual may have been underage at the time content was created, or that age/identity documentation may be fraudulent, altered, or otherwise invalid:

1. -Distribution of the affected content must be suspended where appropriate;
2. -The matter must be immediately escalated to Compliance and Legal;
3. -Access to the relevant material and records must be restricted;
4. -Personnel must not unnecessarily copy, forward, download, or distribute suspected illegal material;
5. -Relevant records should be preserved in accordance with legal and incident-response requirements; and
6. -CPP will make any legally required or appropriate reports to relevant authorities.

The company will prioritize the safety of any potentially affected individual.

20. Suspected Coercion, Trafficking, or Exploitation

If there are credible indications that a performer was coerced, trafficked, threatened, or otherwise exploited:

1. -Production must be paused or stopped where appropriate;
2. -The concern must be escalated immediately;
3. -The performer's safety should be prioritized;
4. -Relevant records should be preserved appropriately;
5. -Distribution may be suspended;
6. -Legal or specialist assistance may be sought; and
7. -Authorities may be notified where required or appropriate.

Personnel must not attempt to conduct an unsafe or unauthorized investigation themselves.

21. Complaints and Consent Challenges

A performer may contact CPP to raise concerns regarding:

1. -Identity verification;
2. -Age verification;
3. -Consent;
4. -The scope of a release;
5. -Unauthorized distribution;
6. -Misuse of content;
7. -Privacy; or
8. -Other production-related concerns.

Reports should be directed to support@real4cash.com

Complaints should be assessed promptly and handled confidentially to the extent reasonably possible.

22. Takedown and Distribution Hold

Where a credible complaint alleges that content was distributed without appropriate consent or authorization, CPP may temporarily restrict the content while the matter is reviewed.

Depending on the outcome, CPP may:

1. -Remove or restrict the content;
2. -Suspend further distribution;
3. -Contact relevant rights holders or performers;
4. -Investigate the underlying documentation;
5. -Correct or supplement records;
6. -Terminate an unauthorized distribution relationship; and
7. -Take additional legal or compliance action where appropriate.

23. Prohibition on Retaliation

CPP prohibits retaliation against individuals who raise a genuine concern regarding:

1. -Age verification;
2. -Identity verification;
3. -Consent;
4. -Coercion;
5. -Exploitation;
6. -Privacy;
7. -Unauthorized distribution; or
8. -Other violations of this Procedure.

Good-faith reporting should not result in adverse treatment.

24. Training

Personnel involved in production, compliance, content review, records management, or distribution should receive appropriate training.

Training may cover:

1. -Age and identity verification;
2. -Recognizing potentially fraudulent identification;
3. -Consent requirements;
4. -Recognizing coercion and exploitation;
5. -Privacy and information security;
6. -Documentation requirements;
7. -Escalation procedures; and
8. -Handling sensitive content and records.

25. Auditing and Quality Control

CPP may periodically audit ID&V and consent records to determine whether required controls are operating effectively.

Audits may include:

1. -Sampling performer files;
2. -Confirming required documentation is present;
3. -Reviewing verification procedures;
4. -Reviewing consent documentation;
5. -Checking distribution authorization;
6. -Testing access controls; and
7. -Reviewing complaints and incidents.

Any material deficiency should be documented and addressed through corrective action.

26. Exceptions

Exceptions to this Procedure require prior approval from an authorized Compliance or Legal representative.

No exception may permit conduct that violates applicable law or involves a minor.

ID&V and Consent Standard

No adult content may be produced or distributed by CPP unless the company has established, through appropriate documentation and procedures, that the individuals depicted are adults, their identities have been appropriately verified, and the required consent and content-use authorization have been obtained.

Where there is a question concerning age, identity, consent, coercion, exploitation, or authorization, the affected production or distribution must be placed on hold and escalated to the appropriate Compliance or Legal personnel.

1. Purpose

CPP is committed to preventing minors from accessing adult-oriented content through websites and online services operated or controlled by the company.

This Site Access Age-Verification Policy establishes the requirements and procedures used to determine whether a visitor meets the applicable minimum age before being permitted to access age-restricted content or services.

The objectives of this Policy are to:

1. -Restrict access to adult content by individuals who do not meet the applicable minimum age;
2. -Apply appropriate age-assurance measures to site visitors;
3. -Protect users' personal information;
4. -Minimize unnecessary collection and retention of identity information;
5. -Provide a clear and consistent access-control process; and
6. -Comply with applicable legal and regulatory requirements.

2. Scope

This Policy applies to:

1. -CPP websites;
2. -Mobile or web applications operated by CPP;
3. -Online platforms and services containing age-restricted content;
4. -Visitors attempting to access age-restricted areas;
5. -Employees and contractors responsible for site administration;
6. -Third-party age-verification providers; and
7. -Other digital services controlled by CPP where age restrictions apply.

3. Minimum Age

Access to adult content is restricted to individuals who meet the applicable legal minimum age.

Unless a higher minimum age is required by applicable law, CPP standard for accessing adult content is 18 years of age or older.

Where local law requires a higher age threshold or additional age-assurance measures, CPP will apply the applicable requirement.

4. Age-Restricted Areas

CPP will identify areas of its websites and services that contain adult or otherwise age-restricted content.

Where technically and legally appropriate:

1. -General, non-restricted areas may remain accessible without full age verification;
2. -Adult-content areas will require the appropriate age-assurance process;
3. -Navigation, previews, thumbnails, descriptions, or promotional material will be handled in accordance with applicable age restrictions; and
4. -Access controls will be applied consistently to restricted areas.

5. Age Verification Requirement

A visitor must successfully complete the required age-assurance process before accessing restricted adult content where age verification is required.

CPP may use one or more appropriate methods, depending on the jurisdiction and service, including:

1. -Age-estimation technology;
2. -Government-issued identification verification;
3. -Approved third-party age-verification services;
4. -Digital identity or credential-based verification;
5. -Other legally permitted age-assurance technologies; or
6. -A combination of methods.

A simple self-declaration of age may not be sufficient where applicable law requires stronger age verification.

6. Verification Process

The site-access process will generally operate as follows:

Step 1 — Access Attempt

The visitor attempts to enter an age-restricted area.

Step 2 — Age Notice

The visitor is informed that the requested content is intended for adults and that age verification may be required.

Step 3 — Verification

The visitor completes the applicable age-assurance process.

Step 4 — Verification Result

The system determines whether the visitor meets the applicable age requirement.

Step 5 — Access Decision

If the visitor successfully satisfies the required age threshold, access may be granted.

If the visitor does not satisfy the requirement or verification cannot be completed, access to restricted content will be denied.

7. Verification Failure

Access will be denied when:

1. -The visitor does not meet the applicable minimum age;
2. -Verification fails;
3. -Required information is not provided;
4. -The verification service cannot establish the required age;
5. -The information provided is inconsistent or unreliable; or
6. -There is a reasonable indication that the visitor may be attempting to circumvent the age-control process.

A verification failure does not necessarily mean that the visitor has acted improperly. The visitor may be permitted to retry verification where appropriate.

8. False Information and Circumvention

Visitors must not:

1. -Misrepresent their age;
2. -Submit another person's identity information;
3. -Circumvent age-verification controls;
4. -Attempt to defeat technical age restrictions;
5. -Use fraudulent credentials; or
6. -Assist a minor in bypassing site-access controls.

CPP may restrict or terminate access where it identifies deliberate attempts to circumvent age controls.

9. Minors

CPP does not knowingly permit minors to access adult-restricted content.

If CPP becomes aware that a minor has gained access to restricted content, it may:

1. -Immediately restrict the relevant account or session;
2. -Investigate the circumstances;
3. -Review and strengthen applicable access controls;
4. -Take appropriate technical measures to prevent recurrence; and
5. -Take any additional action required by applicable law.

Employees should escalate credible concerns regarding a minor's access to the appropriate Compliance, Legal, or Safety function.

10. Privacy and Data Minimization

CPP recognizes that age-verification processes may involve personal information.

The company will seek to use verification methods that collect and retain only the information reasonably necessary to establish whether the visitor meets the applicable age threshold.

Where technically and legally feasible, CPP should favor systems that return a simple age-eligibility result rather than unnecessary identity information.

For example, where appropriate, the verification result may establish only:

“Age requirement satisfied: Yes/No.”

rather than unnecessarily retaining the visitor's full identification document.

11. Verification Provider Requirements

Where a third-party age-verification provider is used, CPP will seek to select providers with appropriate:

1. -Security controls;
2. -Privacy practices;
3. -Verification reliability;
4. -Data-minimization practices;
5. -Retention policies;
6. -Fraud-prevention measures;
7. -Regulatory compliance; and
8. -Incident-response procedures.

Contracts with third-party providers should address appropriate security, confidentiality, privacy, data retention, and incident-notification obligations.

12. Storage and Security

Any age-verification information retained by CPP or its service providers must be protected using appropriate technical and organizational safeguards.

Controls may include:

1. -Encryption;
2. -Access restrictions;
3. -Authentication controls;
4. -Access logging;
5. -Secure data transmission;
6. -Vendor security requirements; and
7. -Secure deletion.

Employees must not copy, download, or retain verification information outside approved systems.

13. Retention

CPP will retain age-verification information only for as long as reasonably necessary for:

1. -Legal compliance;
2. -Security;
3. -Fraud prevention;
4. -Account management;
5. -Dispute resolution; or
6. -Other legitimate business purposes.

Where the law does not require retention of detailed identity information, CPP should consider retaining only the minimum verification result necessary to demonstrate compliance.

Information that is no longer required should be securely deleted or anonymized where appropriate.

14. Cookies and Session Controls

Where applicable, CPP may use cookies, session identifiers, or similar technologies to maintain a visitor's verified-access status.

Such technologies must be implemented in accordance with applicable privacy and cookie requirements.

Age verification should not be treated as permanent where circumstances or legal requirements require the visitor to re-verify.

CPP may require re-verification based on factors such as:

1. -Expiration of a verification session;
2. -Changes in applicable law;
3. -Significant account changes;
4. -Security concerns;
5. -Fraud indicators; or
6. -Technical limitations.

15. Geographic and Jurisdictional Requirements

Age-verification requirements may vary by jurisdiction.

CPP may implement different verification methods or access controls based on:

1. -The visitor's location;
2. -Applicable law;
3. -Regulatory requirements;
4. -The nature of the content;
5. -Risk level; and
6. -Available verification technology.

Where required, CPP may restrict access to adult content entirely in jurisdictions where the company cannot reasonably satisfy applicable requirements.

16. Accessibility

CPP will seek to make its age-verification process reasonably accessible to users with disabilities.

Where appropriate, the company will consider:

1. -Accessible verification interfaces;
2. -Alternative verification methods;
3. -Compatibility with assistive technologies; and
4. -Clear instructions and error messages.

Accessibility measures must not undermine the effectiveness of required age restrictions.

17. Customer Support

Visitors experiencing legitimate problems with age verification may contact support@real4cash.com

Support personnel must not manually bypass age-verification requirements unless an authorized exception process exists and the action is permitted by applicable law.

18. Security and Fraud Monitoring

CPP may monitor age-verification systems for indicators of:

1. -Fraudulent credentials;
2. -Automated attacks;
3. -Repeated failed verification;
4. -Credential sharing;
5. -Account abuse;
6. -Technical circumvention; and
7. -Other attempts to bypass access controls.

Security monitoring must be conducted in accordance with applicable privacy and information-security requirements.

19. Incident Response

A suspected compromise of the age-verification system or unauthorized access to verification information must be escalated according to CPP' security incident-response procedures.

Depending on the circumstances, CPP may:

1. -Restrict affected systems;
2. -Investigate the incident;
3. -Preserve relevant records;
4. -Notify affected parties where required;
5. -Notify regulators or authorities where required; and
6. -Implement corrective security measures.

20. Employee Responsibilities

Employees and contractors responsible for website administration, customer support, compliance, security, or age verification must:

1. -Follow this Policy;
2. -Protect verification information;
3. -Complete required training;
4. -Report suspected bypasses or system weaknesses;
5. -Escalate suspected minor access; and
6. -Never intentionally circumvent age restrictions.

21. Auditing and Testing

CPP may periodically test the effectiveness of its site-access age-verification controls.

Testing may include:

1. -Attempted access using different verification scenarios;
2. -Review of failed-verification rates;
3. -Security testing;
4. -Review of circumvention attempts;
5. -Privacy assessments;
6. -Vendor assessments; and
7. -Verification-system performance reviews.

Material deficiencies should be documented and addressed through corrective action.

22. Policy Enforcement

Violations of site-access age restrictions may result in:

1. -Denial of access;
2. -Account suspension;
3. -Account termination;
4. -Technical restrictions;
5. -Referral to security or compliance personnel; and
6. -Additional action where required or appropriate.

23. Legal and Regulatory Compliance

This Policy is intended to operate alongside applicable federal, state, local, and international laws and regulations.

Where applicable law imposes stricter age-verification requirements, CPP will implement the requirements applicable to the relevant service and jurisdiction.

Legal or regulatory questions concerning age verification should be referred to CPP' Legal or Compliance function.

24. Policy Review

CPP will periodically review this Policy to account for:

1. -Changes in applicable law;
2. -Regulatory developments;
3. -New age-assurance technologies;
4. -Privacy and security developments;
5. -Emerging methods of circumvention;
6. -Changes to CPP' websites or services; and
7. -Findings from audits, incidents, and user feedback.

Site Access Standard

CPP restricts access to adult content to individuals who meet the applicable minimum-age requirement. Where age verification is required, access will not be granted until the visitor successfully completes the designated age-assurance process.

CPP is committed to using proportionate, privacy-conscious age-verification methods and to minimizing the collection and retention of personal information while maintaining effective age restrictions.

Anti-Modern Slavery and Human Trafficking Statement

1. Our Commitment

CPP is committed to conducting its business ethically, responsibly, and in a manner that respects the dignity, safety, and fundamental rights of every individual.

CPP has a zero-tolerance approach to modern slavery, human trafficking, forced labor, servitude, debt bondage, and other forms of exploitation.

This Statement describes the steps CPP takes, and intends to take, to identify, prevent, mitigate, and address the risk of modern slavery and human trafficking within its operations, productions, supply chain, and business relationships.

We expect employees, performers, contractors, suppliers, production partners, distributors, and other business partners to share this commitment.

2. Scope

This Statement applies to CPP business activities and, where appropriate, its relationships with:

1. -Employees;
2. -Performers and models;
3. -Independent contractors;
4. -Production personnel;
5. -Talent agencies and representatives;
6. -Production companies;
7. -Content creators;
8. -Suppliers and vendors;
9. -Distributors and platforms;
10. -Service providers; and
11. -Other third parties acting on behalf of CPP.

3. Our Zero-Tolerance Standard

CPP will not knowingly tolerate or participate in:

1. -Human trafficking;
2. -Forced or compulsory labor;
3. -Slavery or servitude;
4. -Debt bondage;
5. -Labor obtained through threats or coercion;
6. -Recruitment through fraud or deception;
7. -Withholding identity documents to compel work;
8. -Restricting a person's freedom of movement for purposes of exploitation;
9. -Sexual exploitation;
10. -Coercion into sexual activity or content; or
11. -Any other practice that unlawfully deprives an individual of freedom or choice.

Any suspected violation will be treated seriously and may result in suspension or termination of the relevant relationship and, where appropriate or legally required, notification to authorities.

4. Protection of Performers

Because CPP operates in the adult-content production industry, the company recognizes that performers and other production participants may face particular risks relating to coercion, exploitation, trafficking, and abuse.

CPP is committed to ensuring that participation in production is based on:

1. -Verified adulthood;
2. -Appropriate identity verification;
3. -Informed and voluntary consent;
4. -Clear contractual terms;
5. -Appropriate compensation arrangements;
6. -Freedom from coercion and threats; and
7. -Respect for individual safety and dignity.

No individual should be required or pressured to participate in content against their will.

5. Recruitment Practices

CPP expects recruitment and talent-acquisition activities to be conducted honestly and transparently.

Recruitment practices must not involve:

1. -False promises regarding employment or compensation;
2. -Deceptive representations concerning the nature of production;
3. -Threats or intimidation;
4. -Coercive recruitment fees;
5. -Unlawful restrictions on movement;
6. -Retention of personal identification documents for coercive purposes; or
7. -Other practices designed to prevent an individual from freely deciding whether to work or participate.
8. -Where recruitment agencies or talent representatives are used, CPP may conduct appropriate due diligence and require contractual compliance with applicable standards.

6. Consent and Freedom of Choice

Participation in CPP' productions must be voluntary.

CPP prohibits the use of:

1. -Physical force;
2. -Threats;
3. -Intimidation;
4. -Blackmail;
5. -Deception concerning material production terms;
6. -Unlawful financial pressure; or
7. -Other coercive conduct.

A person's agreement to participate in one production or activity must not be treated as unlimited consent to unrelated activities.

Concerns regarding consent, coercion, or exploitation must be escalated promptly.

7. Due Diligence

CPP seeks to identify and address modern-slavery risks through reasonable and proportionate due diligence.

Depending on the nature and risk of the relationship, due diligence may include:

1. -Reviewing supplier and business-partner policies;
2. -Assessing recruitment and employment practices;
3. -Confirming appropriate performer verification and consent procedures;
4. -Reviewing contractual commitments;
5. -Evaluating geographic or industry-specific risks;
6. -Requesting representations or certifications;
7. -Conducting periodic reviews; and
8. -Investigating credible allegations or concerns.

Higher-risk relationships may be subject to enhanced due diligence.

8. Supply Chain Expectations

CPP expects suppliers, contractors, production partners, talent representatives, and other relevant business partners to:

1. -Comply with applicable laws;
2. -Respect fundamental human rights;
3. -Prohibit forced labor and human trafficking;
4. -Maintain appropriate recruitment practices;
5. -Avoid coercive or exploitative working conditions;
6. -Maintain appropriate records; and
7. -Notify CPP of material concerns relating to modern slavery or trafficking.

Where appropriate, these requirements may be incorporated into contracts or supplier agreements.

9. Risk Assessment

CPP recognizes that modern-slavery risks may vary depending on:

1. -The nature of the work;
2. -Recruitment practices;
3. -Geographic location;
4. -Use of third-party labor;
5. -Production arrangements;
6. -Business partners;
7. -Vulnerability of individuals;
8. -Payment practices; and
9. -Other operational factors.

CPP may periodically assess these factors and prioritize higher-risk areas for additional controls.

10. Identification of Potential Exploitation

Personnel should remain alert to indicators that an individual may be subject to trafficking, coercion, or exploitation.

Potential warning signs may include:

1. -A person appearing unable to freely leave a workplace or production;
2. -Another individual controlling the person's identification documents or finances;
3. -Unexplained debt or recruitment obligations;
4. -Threats or intimidation;
5. -A person appearing fearful of a manager, representative, or partner;
6. -Significant discrepancies between agreed and actual working conditions;
7. -Evidence of deception concerning the nature of the work;
8. -A person being prevented from communicating privately; or
9. -Other circumstances suggesting that participation may not be voluntary.

No single indicator necessarily establishes that trafficking or exploitation has occurred. Concerns should nevertheless be escalated for appropriate review.

11. Reporting Concerns

Employees, performers, contractors, suppliers, and other individuals are encouraged to report suspected modern slavery, human trafficking, coercion, or exploitation.

Reports may be made to support@real4cash.com

Reports should be handled promptly and, where possible, confidentially.

Individuals reporting genuine concerns in good faith will not be subject to retaliation.

12. Immediate Safety Concerns

Where an individual may face an immediate threat of physical harm, trafficking, or serious exploitation, safety should take priority.

Employees should not attempt to confront an alleged trafficker or conduct an independent investigation where doing so could place anyone at risk.

The matter should be immediately escalated to the appropriate Compliance, Legal, Security, or management personnel and, where appropriate, emergency services or relevant authorities.

13. Investigation and Remediation

When a credible concern is identified, CPP may:

1. -Conduct an internal investigation;
2. -Engage qualified external advisers;
3. -Suspend relevant production or business activity;
4. -Restrict or suspend distribution;
5. -Protect affected individuals;
6. -Require corrective action;
7. -Suspend or terminate a supplier or business relationship;
8. -Cooperate with law enforcement or other authorities; and
9. -Take other appropriate remedial measures.

CPP will seek to avoid actions that could unintentionally increase the risk to an affected individual.

14. Contracts and Business Relationships

Where appropriate, CPP may include anti-slavery and human-trafficking requirements in agreements with:

1. -Suppliers;
2. -Production partners;
3. -Talent agencies;
4. -Contractors;
5. -Distributors;
6. -Service providers; and
7. -Other relevant third parties.

Contracts may provide for corrective action, audit rights, suspension, or termination where serious violations occur.

15. Training and Awareness

CPP will seek to provide appropriate training and awareness to personnel whose roles may expose them to modern-slavery or trafficking risks.

Training may cover:

1. -Modern slavery and human trafficking;
2. -Coercion and exploitation;
3. -Performer safety;
4. -Recruitment risks;
5. -Warning signs;
6. -Reporting procedures;
7. -Consent and ID&V requirements;
8. -Privacy and confidentiality; and
9. -Appropriate escalation.

Personnel with greater exposure to these risks may receive enhanced training.

16. Record Keeping

CPP may maintain records demonstrating the implementation of its anti-slavery and human-trafficking controls.

Records may include:

1. -Training records;
2. -Supplier assessments;
3. -Contractual commitments;
4. -Performer verification records;
5. -Consent documentation;
6. -Reports and complaints;
7. -Investigation records;
8. -Corrective actions; and
9. -Other relevant compliance documentation.

Records will be handled in accordance with applicable privacy, security, and retention requirements.

17. Privacy and Confidentiality

Information relating to potential trafficking, exploitation, or abuse may be highly sensitive.

CPP will seek to protect such information through appropriate access controls, confidentiality requirements, secure storage, and other reasonable safeguards.

Information should be shared only with individuals who have a legitimate need to know or where disclosure is required or permitted by law.

18. Monitoring and Effectiveness

CPP may monitor the effectiveness of its anti-modern-slavery controls through measures such as:

1. -Training completion;
2. -Supplier and partner assessments;
3. -Compliance reviews;
4. -Reports and complaints;
5. -Investigation outcomes;
6. -Corrective actions;
7. -Verification and consent audits; and
8. -Periodic policy reviews.

The company will use identified weaknesses and lessons learned to improve its practices.

19. Responsibility

Management and relevant personnel are responsible for implementing the requirements applicable to their areas of responsibility.

Employees, contractors, suppliers, and business partners are expected to support CPP commitment to preventing modern slavery and human trafficking.

20. Continuous Improvement

CPP recognizes that modern slavery and human trafficking are complex issues requiring ongoing vigilance.

The company will periodically review this Statement and its related policies and procedures to account for:

1. -Changes in applicable law;
2. -Regulatory developments;
3. -Industry risks;
4. -Changes to production or supply-chain arrangements;
5. -Emerging risks;
6. -Lessons learned from incidents; and
7. -Opportunities to strengthen protections for workers and performers.

Commitment

CPP Inc. has zero tolerance for modern slavery, human trafficking, forced labor, coercion, and exploitation.

We are committed to ensuring that individuals who work with or participate in CPP activities are treated with dignity and respect and are able to make informed and voluntary decisions about their participation.

We expect our employees, performers, suppliers, contractors, production partners, and other business relationships to uphold these principles and to report concerns promptly.

CSAM, Non-Consensual or Illegal Content Policy

1. Purpose

CPP maintains a zero-tolerance approach to child sexual abuse material (“CSAM”), non-consensual sexual content, human exploitation, and other unlawful content.

This Policy establishes the standards and procedures CPP uses to:

1. -Prevent prohibited content from being created, uploaded, published, or distributed;
2. -Identify and restrict potentially prohibited material;
3. -Respond to reports and complaints;
4. -Protect individuals who may be affected by prohibited content;
5. -Preserve relevant information appropriately;
6. -Escalate serious incidents to Legal, Compliance, or appropriate authorities;
7. -Cooperate with lawful investigations; and
8. -Maintain appropriate records of moderation and enforcement actions.

2. Scope

This Policy applies to content created, submitted, acquired, licensed, uploaded, published, distributed, hosted, or otherwise managed by CPP.

It applies to:

1. -Employees;
2. -Performers and creators;
3. -Contractors;
4. -Production partners;
5. -Content licensors;
6. -Distributors;
7. -Website and platform users;
8. -Moderators;
9. -Customer-support personnel; and
10. -Third-party service providers acting on behalf of CPP.

The Policy applies to photographs, videos, livestreams, audio, written material, advertisements, thumbnails, metadata, comments, messages, profiles, and other associated material.

3. Prohibited Content

CPP prohibits content that violates applicable law or this Policy, including:

1. -CSAM;
2. -Sexual content involving minors;
3. -Non-consensual sexual or intimate content;
4. -Content depicting actual sexual assault or sexual abuse;
5. -Content involving trafficking or sexual exploitation;
6. -Content created or distributed through coercion;
7. -Content unlawfully obtained or distributed;
8. -Content that violates applicable criminal law; and
9. -Other material that CPP determines must be prohibited under applicable law or its safety standards.

4. CSAM

CPP has a strict prohibition against CSAM.

CPP will not knowingly:

1. -Create CSAM;
2. -Upload CSAM;
3. -Publish CSAM;
4. -Distribute CSAM;
5. -Facilitate access to CSAM;
6. -Sell or commercialize CSAM; or
7. -Permit its services to be used for the distribution of CSAM.

Any content reasonably suspected of being CSAM must be treated as a high-priority safety and legal matter.

Personnel must not unnecessarily copy, download, forward, save, or distribute suspected CSAM.

5. Response to Suspected CSAM

When suspected CSAM is identified or reported, CPP will take appropriate immediate measures, which may include:

1. -Restricting access to the material;
2. -Preventing further distribution where technically feasible;
3. -Escalating the matter to designated Legal, Compliance, or Trust & Safety personnel;
4. -Preserving relevant information in accordance with applicable law and legal instructions;
5. -Taking steps required by applicable reporting obligations;
6. -Cooperating with appropriate authorities; and
7. -Taking measures to prevent recurrence.

Personnel should not independently investigate suspected CSAM beyond what is necessary to identify and escalate the issue safely.

6. Non-Consensual Sexual or Intimate Content

CPP prohibits the publication or distribution of sexual or intimate content where the person depicted did not provide appropriate consent to the creation or distribution of the material.

This includes, where applicable:

1. -Secretly recorded intimate material;
2. -Unauthorized intimate imagery;
3. -Content distributed after consent was withdrawn where continued distribution is unlawful;
4. -Material obtained through coercion;
5. -Content created through deception concerning material circumstances; and
6. -Unauthorized redistribution of intimate content.

7. Reports of Non-Consensual Content

A person who believes that intimate or sexual content involving them has been published without appropriate consent may contact support@real4cash.com

Reports should provide enough information to identify the material without requiring the reporting individual to repeatedly submit sensitive material.

CPP will review credible reports promptly.

8. Emergency Takedown Measures

Where a report raises a credible concern regarding non-consensual sexual content, CPP may temporarily restrict the relevant content while the matter is reviewed.

Depending on the circumstances, CPP may:

1. -Remove the content;
2. -Restrict public access;
3. -Prevent further distribution;
4. -Disable sharing or embedding;
5. -Suspend the associated account;
6. -Preserve relevant records;
7. -Contact the affected individual where appropriate; and
8. -Escalate the matter to Legal or Compliance.

Safety and prevention of continuing harm will be prioritized.

9. Consent Verification

CPP maintains procedures designed to establish that adults appearing in its content have provided appropriate authorization and consent.

Before publication, appropriate records should establish, as applicable:

1. -Identity;
2. -Age;
3. -Participation;
4. -Consent;
5. -Content-use authorization;
6. -Distribution rights; and
7. -Other legally required permissions.

Content with unresolved material questions regarding consent must not be published until the concern has been appropriately addressed.

10. Coercion and Exploitation

CPP prohibits content involving coercion, trafficking, forced participation, or exploitation.

Potential warning signs may include:

1. -Threats;
2. -Intimidation;
3. -Physical force;
4. -Blackmail;
5. -Unlawful financial pressure;
6. -Trafficking indicators;
7. -A person being prevented from leaving;
8. -Another person controlling identification documents or finances;
9. -Deception concerning the nature of participation; or
10. -Other circumstances indicating that participation may not be voluntary.

Concerns must be escalated promptly.

11. Illegal Content

CPP prohibits content that is unlawful under applicable law.

Where the legality of material is uncertain, the content should be placed on hold where appropriate and referred to Legal or Compliance for assessment.

Employees and moderators should not make complex legal determinations beyond their assigned authority.

12. Content Moderation

CPP may use a combination of automated systems and human review to identify potentially prohibited content.

Moderation controls may include:

1. -Automated content classification;
2. -Hash or digital-signature matching where legally and technically appropriate;
3. -Account and upload monitoring;
4. -User reporting;
5. -Manual review;
6. -Rights-holder complaints;
7. -Performer complaints; and
8. -Other safety mechanisms.

Automated detection may identify material for further review but should not necessarily be treated as a final legal determination.

13. Human Review

Sensitive or high-risk cases should be reviewed by appropriately trained personnel.

Human reviewers should:

1. -Follow established moderation procedures;
2. -Avoid unnecessary exposure to sensitive material;
3. -Access only the information required for their role;
4. -Document material decisions;
5. -Escalate uncertain or high-risk cases; and
6. -Follow applicable evidence-preservation procedures.

14. Handling Sensitive Material

Personnel who encounter potentially illegal or abusive material must minimize unnecessary exposure.

Personnel must not:

1. -Share prohibited material with colleagues who do not need access;
2. -Download material unnecessarily;
3. -Save prohibited material to personal devices;
4. -Send prohibited material through ordinary email or messaging services;
5. -Re-upload material for testing purposes; or
6. -Retain copies outside approved systems.

Where evidence preservation is legally necessary, it must be handled only through authorized procedures.

15. Account and Content Enforcement

Depending on the circumstances, CPP may:

1. -Remove prohibited content;
2. -Restrict content;
3. -Suspend an account;
4. -Terminate an account;
5. -Disable uploading privileges;
6. -Block repeat offenders;
7. -Terminate a business relationship;
8. -Preserve relevant records; and
9. -Refer matters to appropriate authorities.

Enforcement decisions may consider the severity, credibility, frequency, and circumstances of the violation.

16. Appeals

Where appropriate, users may appeal moderation or account-enforcement decisions.

Appeals should identify:

1. -The content or account involved;
2. -The decision being challenged;
3. -The reason for the appeal; and
4. -Relevant supporting information.

CPP may maintain restrictions during an appeal where there is a significant safety, legal, privacy, or consent concern.

Content involving suspected minors or other serious criminal matters may be subject to special handling and may not be eligible for ordinary appeals.

17. Reporting to Authorities

CPP will comply with applicable legal requirements concerning reporting of prohibited content or suspected criminal activity.

Depending on the circumstances, CPP may cooperate with:

1. -Law-enforcement agencies;
2. -Relevant regulatory authorities;
3. -Child-protection organizations;
4. -Courts;
5. -Legal representatives; and
6. -Other authorized bodies.

Reports and disclosures will be handled in accordance with applicable law.

18. Preservation of Information

Where appropriate, CPP may preserve:

1. -Account information;
2. -Upload information;
3. -Moderation records;
4. -Relevant timestamps;
5. -Transaction records;
6. -Communications;
7. -Access logs; and
8. -Other information reasonably necessary for an investigation.

Preservation will be conducted in accordance with applicable law, privacy requirements, and CPP legal-hold procedures.

19. Privacy and Confidentiality

Reports concerning CSAM, non-consensual content, trafficking, or exploitation may contain highly sensitive personal information.

CPP will seek to:

1. -Restrict access to authorized personnel;
2. -Maintain confidentiality;
3. -Use secure storage;
4. -Minimize unnecessary disclosure;
5. -Follow applicable privacy requirements; and
6. -Retain information only as required or reasonably necessary.

20. Protection Against Retaliation

CPP prohibits retaliation against individuals who make good-faith reports concerning:

1. -CSAM;
2. -Non-consensual content;
3. -Coercion;
4. -Trafficking;
5. -Exploitation;
6. -Illegal activity; or
7. -Other content-safety concerns.

Reports should be handled professionally and confidentially to the extent reasonably possible.

21. Third-Party Content

Third parties providing content to CPP must comply with applicable law and CPP content-safety requirements.

CPP may require third parties to provide appropriate representations, warranties, documentation, or certifications concerning:

1. -Performer age;
2. -Identity;
3. -Consent;
4. -Rights;
5. -Lawful production; and
6. -Absence of prohibited content.

Material concerns may result in rejection, suspension, or termination of the relationship.

22. Training

Personnel involved in content moderation, production, compliance, customer support, or platform administration should receive appropriate training.

Training may cover:

1. -Recognizing prohibited content;
2. -CSAM escalation procedures;
3. -Non-consensual-content complaints;
4. -Consent and age verification;
5. -Coercion and trafficking indicators;
6. -Privacy and confidentiality;
7. -Evidence preservation;
8. -Reporting obligations; and
9. -Incident escalation.

23. Monitoring and Auditing

CPP may periodically assess the effectiveness of its content-safety controls.

Reviews may include:

1. -Moderation audits;
2. -Takedown response times;
3. -Complaint handling;
4. -Account enforcement;
5. -Age and consent verification;
6. -Third-party assessments;

Security controls; and

Incident-response performance.

Material deficiencies should be documented and addressed through corrective action.

24. Incident Escalation

The following matters require prompt escalation to the designated Compliance, Legal, or Trust & Safety function:

1. -Suspected CSAM;
2. -Suspected involvement of a minor;
3. -Credible allegations of non-consensual sexual content;
4. -Human trafficking;
5. -Sexual exploitation;
6. -Coercion;
7. -Threats of serious harm;
8. -Significant data breaches involving sensitive content; and
9. -Other potentially serious criminal or safety matters.

25. Employee Responsibilities

Employees and contractors must:

1. -Follow this Policy;
2. -Report suspected violations;
3. -Protect confidential information;
4. -Avoid unnecessary handling of prohibited material;
5. -Follow escalation procedures;
6. -Complete required training; and
7. -Cooperate with authorized investigations.

Employees must not knowingly circumvent content-safety controls.

26. Policy Enforcement

Violations of this Policy may result in:

1. -Content removal;
2. -Access restrictions;
3. -Account suspension;
4. -Account termination;
5. -Termination of employment or contract;
6. -Termination of business relationships;
7. -Legal action; and/or
8. -Referral to appropriate authorities.

27. Policy Review

CPP will periodically review this Policy to reflect:

1. -Changes in applicable law;
2. -Regulatory requirements;
3. -Emerging safety risks;
4. -New moderation technologies;
5. -Privacy developments;
6. -Industry standards; and
7. -Lessons learned from incidents and investigations.

Content Safety Standard

CPP maintains zero tolerance for CSAM, sexual content involving minors, non-consensual sexual or intimate content, trafficking, coercive sexual exploitation, and other unlawful content.

CPP will take appropriate measures to prevent prohibited content from being created or distributed through its services, respond promptly to credible reports, protect affected individuals, and comply with applicable reporting and legal obligations.

Contacting Law Enforcement Guidelines for CSAM and NCMEC Reporting

1. Purpose

CPP maintains a zero-tolerance policy toward child sexual abuse material (“CSAM”) and any sexual exploitation of children.

These Guidelines establish the procedures employees, contractors, moderators, and other authorized personnel must follow when CSAM or suspected child sexual exploitation is identified, reported, discovered, or otherwise brought to CPP attention.

The objectives of these Guidelines are to:

1. -Protect children from further harm;
2. -Prevent the continued distribution of suspected CSAM;
3. -Ensure serious incidents are escalated promptly;
4. -Establish procedures for reporting through the appropriate authorities and reporting channels;
5. -Support lawful investigations;
6. -Preserve relevant information appropriately; and
7. -Prevent employees from unnecessarily viewing, copying, downloading, or distributing suspected CSAM.

2. Scope

These Guidelines apply to:

1. -Employees;
2. -Contractors;
3. -Content moderators;
4. -Trust & Safety personnel;
5. -Compliance personnel;
6. -Customer-support personnel;
7. -Production personnel;
8. -Website administrators;
9. -Third-party service providers acting on behalf of CPP; and
10. -Other personnel who may encounter suspected CSAM through CPP systems or services.

3. Zero-Tolerance Standard

CPP prohibits the creation, production, possession for distribution, upload, publication, transmission, sale, promotion, or distribution of CSAM.

CPP will take appropriate action when suspected CSAM is identified, including restricting access, escalating the matter, preserving relevant information, and making reports required by applicable law.

4. Definition of CSAM

For purposes of these Guidelines, CSAM generally refers to visual or other material depicting or otherwise documenting the sexual exploitation or sexual abuse of a child.

The precise legal definition may vary by jurisdiction.

Personnel should not attempt to make a definitive legal determination regarding whether material constitutes CSAM. If there is a reasonable concern that material may involve the sexual exploitation of a child, it must be escalated under these Guidelines.

5. Immediate Response

When suspected CSAM is identified, personnel should:

1. -Do not redistribute the material.
2. -Do not download or save additional copies.
3. -Do not forward the material to colleagues.
4. -Do not contact or confront the suspected offender.
5. -Do not attempt to independently investigate the individual.
6. -Restrict access to the content where authorized and technically feasible.
7. -Immediately notify the designated Compliance, Legal, or Trust & Safety contact.
8. -Follow applicable reporting and evidence-preservation procedures.

The priority is to prevent further harm while preserving information necessary for lawful investigation.

6. Internal Escalation

Suspected CSAM must be escalated promptly to support@real4cash.com

Personnel should treat suspected CSAM as a high-priority incident.

7. NCMEC CyberTipline

Where applicable, CPP may submit reports of suspected online child sexual exploitation through the National Center for Missing & Exploited Children's (NCMEC) CyberTipline.

The CyberTipline is a U.S. reporting mechanism for suspected child sexual exploitation and related online abuse.

Authorized CPP personnel should use the official NCMEC reporting channel when a report is appropriate and required or authorized by applicable law and company procedures.

Official NCMEC CyberTipline: [NCMEC CyberTipline](https://report.cybertip.org/?utm_source=chatgpt.com)

Personnel should not submit duplicate or unnecessary reports independently unless instructed by Legal, Compliance, or applicable law.

8. Information for a CyberTipline Report

Where legally permissible and reasonably available, an authorized report may include information such as:

1. -The URL or location where the material was identified;
2. -Relevant account or username information;
3. -Date and time of discovery;
4. -Information regarding the account or uploader;
5. -Relevant transaction or access information;
6. -IP address or technical information where lawfully available;
7. -Relevant communications or metadata;
8. -Information concerning how the material was discovered; and
9. -Other information requested by the reporting authority.

CPP should provide accurate information and should not speculate beyond the facts reasonably available.

9. Handling the Material Itself

Personnel must minimize unnecessary exposure to suspected CSAM.

Unless specifically authorized under an applicable evidence-preservation procedure, personnel must not:

1. -Download suspected CSAM;
2. -Create screenshots unnecessarily;
3. -Send suspected CSAM by email;
4. -Upload it to another service;
5. -Place it on personal devices;
6. -Print it;
7. -Share it through messaging applications; or
8. -Create additional copies for internal review.
9. -Where evidence must be preserved, preservation should be handled by authorized personnel using approved systems and procedures.

10. Law-Enforcement Contact

CPP may contact appropriate law-enforcement authorities when:

1. -Reporting is legally required;
2. -There is an immediate threat to a child;
3. -There is evidence of an ongoing criminal offense;
4. -A law-enforcement agency requests information;
5. -Legal counsel determines that direct reporting is appropriate; or
6. -Other circumstances make law-enforcement notification appropriate.

Depending on the circumstances, relevant authorities may include:

1. -Local law enforcement;
2. -State or federal law-enforcement agencies;
3. -The Federal Bureau of Investigation;
4. -Homeland Security Investigations;
5. -Other appropriate governmental authorities; and/or
6. -Authorities in another jurisdiction where legally appropriate.

11. Immediate Danger to a Child

If there is credible information indicating that a child faces an immediate threat of serious harm, personnel should treat the matter as an emergency.

Where appropriate, authorized personnel should contact the relevant emergency or law-enforcement authority immediately.

Emergency: Call 911 in the United States when there is an immediate threat requiring emergency assistance.

Employees should not delay an emergency response while waiting for an internal review if doing so could place a child at greater risk.

12. NCMEC and Law Enforcement

A report to NCMEC does not necessarily replace other reporting or notification obligations that may apply to CPP.

Legal or Compliance personnel should determine whether additional reporting is required under applicable federal, state, local, or international law.

Where appropriate, CPP may cooperate with both NCMEC and law-enforcement authorities.

13. Preservation of Relevant Information

When suspected CSAM is identified, CPP should preserve relevant information when legally appropriate and reasonably necessary for reporting or investigation.

Relevant information may include:

1. -Account information;
2. -Usernames;
3. -URLs;
4. -Upload records;
5. -Dates and timestamps;
6. -IP addresses where lawfully retained;
7. -Transaction information;
8. -Communications;
9. -Device or technical information where lawfully available;
10. -Moderation records; and
11. -Other information reasonably relevant to the investigation.

Preservation must be conducted in accordance with applicable law, privacy requirements, and CPP legal-hold procedures.

14. Legal Holds

Where Legal determines that litigation, regulatory proceedings, or law-enforcement investigation may be reasonably anticipated, CPP may issue a legal hold.

Personnel receiving a legal hold must preserve information covered by the hold and must not delete, modify, or destroy relevant records.

15. Confidentiality

Reports involving suspected CSAM are highly sensitive.

Personnel must keep such matters confidential and share information only with:

1. -Authorized Compliance or Legal personnel;
2. -Designated Trust & Safety personnel;
3. -Appropriate investigators;
4. -Law-enforcement authorities;
5. -NCMEC where appropriate; or
6. -Other parties with a legitimate legal or operational need to know.

Personnel must not publicly discuss an investigation or notify a suspected offender that a report has been submitted unless authorized by Legal or the relevant authorities.

16. Do Not Alert the Suspected Offender

Personnel must not contact, warn, threaten, or confront an individual suspected of uploading or distributing CSAM.

This includes:

1. -Sending warning messages;
2. -Threatening account termination;
3. -Asking the individual to explain the material;
4. -Informing the individual that law enforcement has been contacted; or
5. -Providing information that could compromise an investigation.

Account restrictions or other enforcement actions should be coordinated with Legal, Compliance, or Trust & Safety where appropriate.

17. Account and Content Restrictions

CPP may restrict or suspend an account associated with suspected CSAM.

Depending on legal and investigative considerations, actions may include:

1. -Removing public access;
2. -Suspending an account;
3. -Disabling uploads;
4. -Blocking further distribution;
5. -Restricting account functionality; or
6. -Terminating the account.
7. -Before permanently deleting information, CPP should consider whether preservation is required or appropriate for a potential investigation.

18. Reporting by Employees

Employees who independently encounter suspected CSAM must report it immediately through the company's designated reporting channel.

Employees should not attempt to determine whether the material is definitively illegal.

A good-faith concern is sufficient to trigger internal escalation.

19. Third-Party Reports

CPP may receive reports from:

1. -Users;
2. -Performers;
3. -Parents or guardians;
4. -Rights holders;
5. -Law enforcement;
6. -NCMEC;
7. -Other platforms;
8. -Service providers; or
9. -Other third parties.

Reports should be escalated according to the same high-priority procedures when they raise a credible concern regarding child sexual exploitation.

20. Requests from Law Enforcement

If law enforcement requests information relating to suspected CSAM or child exploitation, the request should be promptly referred to Legal or an authorized Compliance representative.

CPP should verify the request and respond in accordance with:

1. -Applicable law;
2. -Valid legal process;
3. -Privacy requirements;
4. -Internal procedures; and
5. -Any applicable preservation obligation.
6. -Personnel must not voluntarily disclose sensitive user information outside their authority.

21. International Matters

Child exploitation laws and reporting obligations vary by jurisdiction.

Where content, users, performers, infrastructure, or business operations involve multiple countries, CPP will consult Legal regarding applicable reporting and disclosure obligations.

CPP may cooperate with appropriate authorities in other jurisdictions where legally required or appropriate.

22. Training

Personnel who may encounter user-generated content or sensitive reports should receive appropriate training on:

1. -Recognizing potential CSAM;
2. -Immediate escalation;
3. -NCMEC CyberTipline procedures;
4. -Law-enforcement requests;
5. -Evidence preservation;
6. -Privacy and confidentiality;
7. -Avoiding unnecessary handling of suspected CSAM; and
8. -Child-safety responsibilities.

Specialized personnel may receive additional training appropriate to their roles.

23. Protection Against Retaliation

CPP prohibits retaliation against an employee or contractor who makes a good-faith report concerning suspected child exploitation or CSAM.

Reports should be handled professionally and confidentially to the extent reasonably possible.

24. Record Keeping

CPP will maintain appropriate records concerning:

1. -Internal reports;
2. -Escalations;
3. -Reporting decisions;
4. -NCMEC submissions where applicable;
5. -Law-enforcement requests;
6. -Preservation actions;
7. -Account actions; and
8. -Related investigations.

Records must be protected against unauthorized access and retained in accordance with applicable law and CPP records-retention requirements.

25. Periodic Review

CPP will periodically review these Guidelines to account for:

1. -Changes in applicable law;
2. -NCMEC reporting procedures;
3. -Law-enforcement guidance;
4. -Emerging child-safety risks;
5. -Changes to CPP' services;
6. -Technological developments; and
7. -Lessons learned from incidents.

CSAM Reporting Standard

CPP maintains zero tolerance for CSAM and child sexual exploitation. Any suspected CSAM must be treated as a high-priority safety and legal matter, escalated immediately, handled with the minimum necessary exposure, and reported to NCMEC and/or appropriate law-enforcement authorities when required or appropriate under applicable law.

Personnel must never knowingly create, distribute, or unnecessarily copy suspected CSAM, and must not alert a suspected offender or interfere with a potential investigation.