Content Moderation Policy

This Content Moderation Policy (the “Policy”) establishes the rules regarding what type of content is permitted on the IcloneU platform, how IcloneU acts upon violations, and user rights in response to such actions. This Policy complies with the requirements of the social media platforms with which IcloneU integrates (Meta, Google, Telegram and others), with the European Union Digital Services Act (DSA), and with applicable legislation in the countries where IcloneU operates.

1. Scope

This Policy applies at two levels:

• Client knowledge library content: all material the client uploads to their knowledge library to train their Digital Clone, including documents, texts, images, videos, links and any other type of file.
• Responses generated by the Digital Clone: the responses the Digital Clone generates on behalf of the client on social media, messaging applications and websites, based on the library content.

The client is solely responsible for the content they upload to their library and for the responses they approve and publish through the platform. IcloneU acts as a technology provider and does not proactively review or moderate library content, except in the cases established in this Policy.

2. Prohibited Content

It is strictly prohibited to upload to the knowledge library, train the Digital Clone with, or generate responses containing any of the following types of content:

2.1 Illegal content

• Content that infringes copyrights, trademarks or other third-party intellectual property rights without proper authorization.
• Content that violates data protection or privacy laws of third parties.
• Content that promotes, facilitates or incites the commission of crimes or illegal activities.
• Content related to illegal financial activities, fraud, money laundering or terrorist financing.

2.2 Harmful or dangerous content

• Content that incites violence, hatred or discrimination based on race, ethnicity, nationality, religion, gender, sexual orientation, disability or other protected characteristics.
• Content that promotes terrorism, violent extremism or groups advocating violence.
• Content that promotes, glorifies or facilitates physical harm to people or animals.
• Content that promotes suicide, self-harm or eating disorders.
• Sexually explicit or pornographic content.
• Any sexual content involving minors (CSAM), which will be immediately reported to the competent authorities.

2.3 Deceptive or manipulative content

• False, misleading or fabricated information that may mislead end users about products, services, facts or people.
• Content designed to impersonate individuals, brands or entities without authorization.
• Phishing content, scams or any attempt to obtain personal information from end users in a deceptive manner.
• Deceptive advertising or advertising that does not comply with applicable consumer protection laws.

2.4 Content that violates platform policies

• Content that violates the terms of service of Meta (Facebook, Instagram, WhatsApp), Google (YouTube), Telegram or any other platform with which IcloneU integrates.
• Content designed to artificially manipulate engagement, algorithms or metrics of social media platforms.
• Spam or mass sending of unsolicited messages.

2.5 Content that compromises security

• Malicious code, viruses, malware or any software designed to damage computer systems.
• Content that exposes personal data of third parties without their consent (doxxing).
• Content that facilitates unauthorized access to computer systems or third-party accounts.

3. Sensitive Message Detection

IcloneU has an automatic sensitive message detection system that identifies communications where the end user may be at risk, including expressions of distress, emotional crisis, suicidal ideation or immediate danger.

Upon detection of a sensitive message:

• The message is never answered automatically.
• The system immediately notifies the client so it can be attended to by a person.
• IcloneU provides the client with a suggested response aimed at directing the user toward professional help resources.

IcloneU makes its best effort to detect this type of message but does not guarantee detection of 100% of cases. The client assumes responsibility for monitoring their platform and addressing risk situations in a timely manner.

4. Actions upon Violations

When IcloneU detects or receives a report of a possible violation of this Policy, it will act proportionally to the severity of the case, applying the following measures in order of severity:

Level 1 — Warning

For minor or first-time violations. IcloneU will notify the client by email explaining the detected violation and requesting correction within 5 business days.

Level 2 — Removal of specific content

If the client does not correct the violation after the warning, or for moderate violations, IcloneU may remove the specific content from the client’s library that violates this Policy, notifying the client of the action taken and its justification.

Level 3 — Temporary suspension

For serious or repeat violations. IcloneU may temporarily suspend the client’s access to the platform for a determined period, notifying the client by email with the duration of the suspension and the conditions for its lifting.

Level 4 — Permanent cancellation

For very serious, repeated violations or those involving illegal content. IcloneU may permanently cancel the client’s account without right to refund, notifying the client by email with the justification for the cancellation.

5. Appeals Process

The client has the right to appeal any moderation decision made by IcloneU within 10 business days following notification of the measure applied.

To appeal, the client must:

• Send an email to legal@icloneu.ai with the subject “Appeal of moderation decision”.
• Include their name, registered email, date of the notification received and the arguments supporting their appeal.
• Attach any supporting evidence or documentation.

IcloneU will review the appeal and communicate its resolution within 15 business days of receipt. The resolution of the appeal will be final.

During the appeal process for a temporary suspension, access to the platform will remain suspended until resolution. In the case of permanent cancellations for serious illegal content, no appeal is permitted.

6. How to Report Inappropriate Content

Any end user or third party who detects inappropriate content generated by an IcloneU Digital Clone may report it through:

• Email: wecare@icloneu.ai with the subject “Inappropriate content report”
• Web form: available at https://icloneu.ai/report

IcloneU will acknowledge receipt of the report within 48 hours and will take corresponding measures in accordance with this Policy. Reports will be treated confidentially.

7. Client Responsibility

The client is solely responsible for the content they upload to their knowledge library and for the responses they approve and publish through the platform. IcloneU assumes no liability for:

• The content of the client’s library.
• Responses approved and published by the client.
• The client’s failure to comply with the terms of service of the social media platforms where their Digital Clone operates.
• Damages caused to third parties by the client’s improper use of the platform.

The client agrees to hold IcloneU harmless from any claim, demand or legal action arising from the content of their library or the responses generated by their Digital Clone.

8. Compliance with Social Media Platforms

IcloneU complies with the usage policies and community standards of the platforms with which it integrates, including Meta’s Usage Policies, Google’s Platform Policies and Telegram’s terms of use. The client is responsible for ensuring that their use of IcloneU complies with the terms of service of each platform where their Digital Clone operates.

If a social media platform notifies IcloneU of a violation related to a client’s account, IcloneU may take the measures established in Section 4 of this Policy immediately and without prior warning.

9. Modifications to this Policy

IcloneU reserves the right to modify this Policy at any time to adapt to legal, regulatory or integrated platform policy changes. For material changes, clients will be notified at least 15 calendar days in advance via the email address registered in their account.

10. Contact

For any queries related to this Policy:

• Content reports: wecare@icloneu.ai
• Appeals and legal matters: legal@icloneu.ai
• Website: www.icloneu.ai

Hermes AI, S.A.P.I. de C.V., commercially IcloneU
Calle Corbeta 21, Colonia Lomas del Chamizal, Cuajimalpa de Morelos, C.P. 05129, Mexico City, Mexico