Complaint Handling Policy

1. Purpose and Scope

This Complaint Handling Policy ("Policy") sets out how PLADA TECHNOLOGIES LTD ("the Company") receives, acknowledges, investigates, and resolves complaints raised by users, subscribers, performers, content partners, employees, and members of the public. It applies to all complaint channels (in-app, email, phone, social media, regulator- or payment-processor-forwarded complaints, and legal correspondence) and to all staff, contractors, and vendors involved in handling them.

This Policy exists to ensure every complaint is:

• Received through an accessible, well-publicized channel and acknowledged promptly.
• Triaged by severity and routed to the team best equipped to resolve it.
• Investigated fairly, consistently, and without retaliation against the complainant.
• Resolved within a defined timeframe, with the outcome and reasoning documented.
• Escalated appropriately when it touches on legal risk, safety, or regulatory obligations.

Where a complaint alleges or suggests child sexual abuse material (CSAM), non-consensual content, trafficking, or coercion, this Policy operates alongside, and never in place of, the Company's Content Monitoring & Trust and Safety Policy. Such complaints are simultaneously routed to Tier 1 content-safety handling regardless of how they were originally submitted.

2. Definitions

• Complaint: any expression of dissatisfaction, whether verbal or written, alleging that the Company's platform, content, staff, or a performer/partner has caused harm, breached policy, breached law, or fallen short of a reasonable service standard.
• Complainant: the person or entity raising the complaint. May be a user, performer, employee, payment processor, regulator, advocacy organization, or member of the public who is not a registered user.
• Respondent: the individual, account, content item, or internal team that is the subject of the complaint.
• Severity Tier: the Critical/High/Standard/Low classification (Section 5) that determines acknowledgment and resolution timeframes.
• Substantiated Complaint: a complaint where the investigation finds sufficient evidence that the alleged conduct or issue occurred.
• Vexatious Complaint: a complaint made in bad faith, repeatedly, or without reasonable basis, intended to harass a respondent or burden the process (handled per Section 11).

3. Guiding Principles

• Accessibility: complainants should not need to be a paying subscriber, or even a registered account holder, to submit a complaint about content, conduct, or safety.
• Good faith and no retaliation: no complainant, witness, or performer is penalized, demonetized, suspended, or otherwise disadvantaged for raising a good-faith complaint.
• Impartiality: complaints are investigated by someone without a conflict of interest in the outcome; complaints about a moderator or manager are escalated to someone outside that person's reporting line.
• Proportionality: the depth of investigation and the remedy applied match the severity and evidence, not the loudness or persistence of the complaint alone.
• Transparency to the complainant: complainants are told the status of their complaint and, subject to privacy and confidentiality limits, the outcome and rationale.
• Confidentiality: complaint details, identities of complainants and witnesses, and investigation findings are shared only on a need-to-know basis, except where disclosure is legally required.
• Documentation: every complaint, however resolved, is logged with a unique case ID, timestamps, actions taken, and outcome.

4. Complaint Categories

• Content and safety complaints: suspected CSAM, non-consensual content, trafficking/coercion indicators, underage-appearing performers, content posted without consent, harassment via comments/messages.
• Performer and partner complaints: disputes over consent, compensation, contract terms, unauthorized re-use or distribution of a performer's likeness, misrepresentation of a studio/partner.
• Account and billing complaints: unauthorized charges, failed cancellations, subscription/refund disputes, chargebacks, identity theft or account takeover.
• Harassment and discrimination complaints: complaints from users, performers, or employees alleging harassment, discrimination, bullying, or hostile conduct by staff, moderators, or other users.
• Technical and service complaints: outages, broken features, accessibility barriers, data/privacy concerns, and general service-quality issues.
• Regulatory and legal complaints: complaints forwarded by payment processors, app-store platforms, regulators, or law enforcement, and formal legal correspondence (demand letters, subpoenas).

5. Intake Channels and Severity Triage

Complaints may be submitted through: an in-app/website 'Report' or 'Complaint' form (no login required for content-safety complaints); a dedicated complaints email address; a phone line for urgent safety matters; and referrals forwarded by payment processors, app stores, or regulators. Every complaint is logged in the case-management system within one business hour of receipt and assigned a severity tier:

Complaints that could plausibly fall into more than one tier are always assigned the higher (more urgent) tier pending initial review.

6. Acknowledgment and Communication with the Complainant

• Every complainant receives a case reference number and an acknowledgment within the timeframe set out in Section 5, regardless of eventual outcome.
• Complainants are given a named or role-based point of contact and a realistic estimate of when they will hear back next.
• Where an investigation will exceed its target resolution time, the complainant is proactively updated with a revised timeframe rather than left to follow up.
• Communications are written in plain language, avoid unnecessary internal jargon, and, for sensitive matters, are handled through a private channel rather than public reply.

7. Investigation Process

7.1 Assignment

Each complaint is assigned to an investigator with no personal or reporting-line conflict of interest in the outcome. Complaints about a specific employee, moderator, or manager are escalated to that person's manager's manager or to Human Resources, never handled by a direct peer or subordinate of the respondent.

7.2 Evidence Gathering

• Relevant account activity, content, moderation logs, payment records, and communications are collected and preserved before any respondent is contacted, to prevent loss or alteration of evidence.
• The respondent is given a fair opportunity to respond to the substance of the complaint, except where doing so would itself create a safety risk (e.g., tipping off a suspected trafficker) or interfere with a law-enforcement referral, in which case Legal and Trust & Safety leadership approve any deviation from standard notice.
• Witnesses, where identified, are interviewed separately and their accounts are documented.

7.3 Determination

The investigator documents a finding of substantiated, unsubstantiated, or inconclusive, with supporting rationale, and records any remedial action taken (content removal, account warning/suspension/termination, refund, policy clarification, referral to law enforcement, etc.).

8. Escalation

• Legal escalation: complaints involving potential litigation, regulatory inquiry, law-enforcement interest, or statutory reporting obligations (e.g., suspected CSAM, trafficking) are escalated immediately to Legal and Trust & Safety leadership, in parallel with, not instead of, standard investigation.
• Executive escalation: complaints involving a senior leader, a systemic pattern affecting many users, or significant reputational/regulatory risk are escalated to the designated executive sponsor (Section 13).
• Cross-functional escalation: billing complaints implicating fraud are looped in with Finance/Payments; harassment complaints implicating a performer's safety are looped in with the performer-support function.

9. Remedies

Available remedies include, as appropriate to the finding: content removal or relabeling, account warning, suspension, or permanent termination, refunds or billing corrections, formal apology or correction, policy or process changes, referral to law enforcement or a regulator, and, for substantiated employee misconduct, disciplinary action up to and including termination.

Remedies are proportionate to the severity and pattern of the substantiated conduct, and prior similar findings against the same respondent are considered when determining the outcome.

Where a complaint is substantiated and involves a possible pattern across multiple complaints, the case is flagged for a broader review rather than treated as an isolated incident.

10. Confidentiality and Data Protection

• Complaint records, including complainant and witness identities, are restricted to personnel directly involved in intake, investigation, or required legal/regulatory reporting.
• Complainant identity is withheld from the respondent unless disclosure is necessary for a fair investigation and does not create a safety risk, or unless legally compelled.
• All complaint data is handled in accordance with the Company's data protection and privacy policies and retained per Section 14.

11. Anti-Retaliation and Vexatious Complaints

• Retaliation against a complainant, witness, or performer for raising a good-faith complaint is itself a violation of this Policy and subject to disciplinary or account action against the retaliating party.
• Complaints later found to be vexatious, fabricated, or submitted in bad faith to harass a respondent do not, by themselves, justify retaliation, but may result in account action against the complainant where the fabrication itself violates platform terms.
• Any employee who believes they are experiencing retaliation may raise this directly with Human Resources or through the confidential ethics/whistleblower channel referenced in Section 13.

12. Appeals

• A complainant or respondent who disagrees with the outcome may request one appeal, reviewed by a person not involved in the original investigation, within the timeframe stated in the outcome communication (default 10 business days from notification).
• Appeals are not available where the underlying finding involves confirmed CSAM or confirmed non-consensual content, consistent with the Content Monitoring & Trust and Safety Policy.
• Appeal decisions are final and are communicated in writing with a brief rationale.

13. Roles and Responsibilities

• Complaint Intake Team: logs, categorizes, and performs initial severity triage on all incoming complaints.
• Trust & Safety: owns content- and safety-related complaints, including all Critical-tier and content-adjacent High-tier cases.
• Customer Operations: owns billing, account, and general service complaints.
• Human Resources: owns complaints involving employee conduct, harassment, or discrimination, and the anti-retaliation channel.
• Legal / Compliance: reviews all Critical-tier complaints, all regulatory/law-enforcement referrals, and any complaint with potential litigation exposure.
• Executive Sponsor (e.g., Chief Trust & Safety Officer or equivalent): owns this Policy, reviews aggregate complaint metrics quarterly, and approves material changes.

14. Record-Keeping

• Every complaint is logged with a unique case ID, intake channel, severity tier, investigator, findings, remedy, and all complainant/respondent communications.
• Complaint records are retained for a minimum of 3 years, or longer where the complaint relates to a matter with an ongoing legal, regulatory, or law-enforcement interest, or where required by applicable record-retention law.
• Aggregate, de-identified complaint data (volume, category, resolution time, substantiation rate) is compiled monthly for management reporting and trend analysis.

15. Reporting and Continuous Improvement

• Trust & Safety and Customer Operations leadership review complaint volume, category trends, and resolution-time performance monthly.
• Recurring or systemic issues identified through complaints (e.g., a repeated billing error, a moderation blind spot) trigger a root-cause review and corrective action plan, tracked to completion.
• Complaint-handling metrics are included in the quarterly report to senior leadership referenced in the Content Monitoring & Trust and Safety Policy.

16. Policy Review and Amendment

This Policy is reviewed at least annually, and additionally whenever there is a material change in applicable law, complaint volume/patterns, or organizational structure. Amendments are version-controlled, dated, and approved by the Policy Owner and Legal Counsel before taking effect.