APPEALS POLICY
Operated by Presstige LLC
Effective date: 1 February 2025
Purpose
FanzCentral (“Platform”), operated by Presstige LLC (“Company,” “we,” “our,” or “us”), is committed to protecting the rights, safety, privacy, dignity, and lawful interests of individuals whose image, likeness, identity, voice, appearance, performance, or other identifying characteristics may appear in content hosted on the Platform.
This Appeals Policy establishes procedures for requesting review, investigation, restriction, removal, or other appropriate action regarding content where a person alleges that:
- Consent was not provided;
- Consent cannot be substantiated;
- Consent was obtained through fraud, coercion, misrepresentation, or other improper means;
- Consent is otherwise legally invalid;
- The content depicts or represents the individual without authorization;
- The content unlawfully uses the individual’s image, likeness, identity, voice, persona, or other identifying characteristics; or
- The content otherwise violates applicable laws, Platform policies, Community Guidelines, payment processor requirements, or the rights of the affected individual.
This Policy also establishes procedures for the review and resolution of appeals relating to content hosted on the Platform.
1. Persons Eligible to Submit an Appeal
An appeal may be submitted by:
- A person depicted in content hosted on the Platform;
- A person whose image, likeness, appearance, identity, voice, persona, performance, or other identifying characteristics are depicted, portrayed, represented, reproduced, simulated, imitated, or otherwise incorporated into content hosted on the Platform;
- A duly authorized legal representative acting on behalf of such person; or
- Any individual otherwise authorized by applicable law to act on behalf of the affected person.
For purposes of this Policy, a “Depicted Person” includes any individual whose image, likeness, appearance, voice, identity, persona, performance, or other identifying characteristics are depicted, portrayed, represented, reproduced, simulated, imitated, or otherwise incorporated into content hosted on the Platform, whether through photographs, videos, audio recordings, digital manipulation, synthetic media, artificial intelligence, or other means.
2. Grounds for Appeal
A Depicted Person may submit an appeal where they reasonably believe that:
- They did not consent to the creation, publication, distribution, display, sale, licensing, monetization, or other use of the content;
- The consent relied upon by the Creator is invalid, fraudulent, forged, coerced, misleading, incomplete, or otherwise unenforceable;
- The content was created or uploaded in violation of applicable laws;
- The content contains false, manipulated, impersonated, synthetic, altered, or misleading representations of the individual;
- The content unlawfully uses the individual’s image, likeness, voice, identity, persona, or identifying characteristics;
- The content depicts human trafficking, coercion, exploitation, abuse, or other unlawful conduct;
- The content depicts a minor or may involve age-verification failures; or
- The content otherwise violates the rights of the affected individual.
3. Submission of Appeals
Appeals shall be submitted to: Email: complaints@fanzcentral.com. The appeal should include, where applicable:
- Full name of the appellant;
- Contact information;
- Government-issued identification;
- A recent photograph or other information reasonably necessary to verify identity;
- Links, URLs, screenshots, or other information identifying the content;
- A detailed description of the grounds for the appeal;
- Any supporting documentation or evidence; and
- Any other information reasonably requested by the Company to facilitate its investigation.
The Company reserves the right to request additional information where reasonably necessary to verify identity, assess the appeal, investigate the allegations, or protect against fraudulent or malicious submissions.
4. Appeal Acknowledgement & Initial Review
The Company shall make reasonable efforts to acknowledge receipt of an appeal within forty-eight (48) hours.
The Company shall endeavor to commence an initial review within three (3) business days of receipt of the appeal.
Where the appeal appears incomplete, the Company may request additional information before proceeding with its review.
The submission of an appeal does not guarantee removal of content, but all appeals shall be reviewed in accordance with this Policy.
5. High-Risk Appeals
An appeal shall be treated as a High-Risk Appeal where it involves allegations of:
- Lack of consent;
- Invalid consent;
- Forged consent documentation;
- Human trafficking;
- Coercion or exploitation;
- Non-consensual intimate content;
- Unauthorized use of image, likeness, identity, voice, persona, or identifying characteristics;
- Impersonation or synthetic media;
- Age-verification failures;
- Underage participation; or
- Any other conduct reasonably deemed by the Company to present a significant legal, safety, compliance, or reputational risk.
High-Risk Appeals shall receive expedited review and may be subject to immediate protective measures pending investigation.
6. Temporary Restriction of Content Pending Investigation
Upon receipt of a High-Risk Appeal, the Company may immediately disable, restrict, de-list, demonetize, remove from public view, or otherwise limit access to the disputed content pending completion of its investigation.
Such temporary action shall not constitute a final determination of the appeal and shall be undertaken solely to protect affected individuals, preserve evidence, facilitate investigation, and comply with applicable laws, payment processor requirements, and Platform policies.
The Company may also temporarily suspend monetization of the disputed content during the investigation.
7. Creator Notification & Request for Documentation
Where appropriate, the Company may notify the Creator of the appeal and request information or documentation relevant to the investigation. The Company may require the Creator to provide:
- Age-verification records;
- Consent documentation;
- Model releases;
- Identity verification records;
- Communications relevant to consent;
- Records demonstrating authority to publish or monetize the content; and
- Any other information reasonably necessary to investigate the appeal.
The Creator shall cooperate fully and promptly with any investigation conducted pursuant to this Policy.
8. Deadline for Submission of Documentation
Unless a shorter period is required due to legal, regulatory, safety, or compliance concerns, a Creator shall provide requested documentation within five (5) business days of the Company’s request.
Failure to provide requested documentation within the specified period may result in continued restriction of the content, removal of the content, suspension of monetization, account suspension, account termination, or any other enforcement action deemed appropriate by the Company.
9. Consent Investigation Process
Upon receipt of an appeal, the Company may conduct such investigation as it reasonably considers necessary. The investigation may include:
- Review of the appeal submission;
- Verification of the identity of the appellant;
- Review of content associated with the appeal;
- Review of age-verification records;
- Review of consent documentation;
- Review of communications and supporting evidence;
- Requests for additional information from the appellant or Creator;
- Consultation with compliance professionals, legal counsel, payment processors, regulators, law enforcement authorities, or other appropriate third parties; and
- Any other investigative measures reasonably necessary to determine the validity of the appeal.
The Company shall assess whether valid consent existed, whether such consent can be substantiated, and whether the content complies with applicable laws, Platform policies, Community Guidelines, and payment processor requirements.
10. Determination of Appeals
Following completion of its investigation, the Company shall determine whether:
- Valid consent existed;
- Valid consent can be substantiated through reliable documentation or evidence;
- The content complies with applicable laws, Platform policies, Community Guidelines, and payment processor requirements; and
- Any corrective or enforcement action is required.
The Company shall endeavor to issue a determination within thirty (30) calendar days of receiving all information reasonably necessary to complete its review.
Where additional investigation is required, the review period may be extended for a reasonable period where necessary to ensure a fair and thorough investigation.
11. Failure to Establish Valid Consent
Where the Company determines that valid consent did not exist, cannot be substantiated, was obtained through fraud, coercion, misrepresentation, forgery, or is otherwise legally invalid, the disputed content shall be removed from the Platform.
The Company may also suspend monetization, suspend the associated account, terminate the associated account, preserve evidence, notify payment processors, cooperate with regulators or law enforcement authorities, or take any other action reasonably deemed necessary.
12. Requests to Withdraw Previously Granted Consent
A Depicted Person may request withdrawal of previously granted consent.
The submission of such a request shall not automatically require removal of content.
The Company shall review such requests on a case-by-case basis, taking into consideration:
- The nature and scope of the original consent;
- Any consent documentation or agreements provided;
- Applicable laws and regulations;
- The rights and interests of affected parties;
- Privacy, safety, and compliance considerations; and
- Any other circumstances reasonably deemed relevant by the Company.
Following review, the Company may approve, deny, or partially grant the request as it considers appropriate and consistent with applicable law and Platform obligations.
13. Appeal Outcomes
Upon completion of its review, the Company may:
- Deny the appeal;
- Request additional information;
- Remove the disputed content;
- Restrict access to the disputed content;
- Disable monetization of the disputed content;
- Issue warnings;
- Suspend accounts;
- Terminate accounts;
- Refer the matter to payment processors, regulators, law enforcement authorities, or other appropriate third parties; or
- Take any combination of the foregoing actions.
The nature and extent of any enforcement action shall be determined having regard to the severity, frequency, and circumstances of the violation.
14. Independent Review
Where a dispute concerning consent, identity, depiction, likeness, authorship, or removal of content remains unresolved following the Company’s investigation, the Company may refer the matter for independent review.
For purposes of this Policy, an Independent Reviewer may include a qualified attorney, mediator, compliance consultant, content moderation specialist, digital rights professional, dispute-resolution professional, or other suitably qualified independent person selected by the Company who has no material involvement in the underlying dispute.
The reasonable costs of such review shall be borne by the Company.
The Independent Reviewer may review relevant records, submissions, evidence, communications, consent documentation, age-verification records, and any other materials reasonably necessary to assess the dispute.
The Company may consider the recommendations of the Independent Reviewer in reaching a final determination.
15. Notice of Determination
Where reasonably practicable, the Company may notify the appellant and any affected Creator that a determination has been reached.
The information disclosed regarding any determination may be limited by privacy obligations, legal requirements, security concerns, regulatory obligations, or the rights of third parties.
16. Record Retention
The Company may retain appeal records, investigation records, communications, supporting documentation, consent records, age-verification records, enforcement records, and related materials for such period as is reasonably necessary to satisfy legal, regulatory, compliance, audit, security, operational, and payment processor requirements.
17. Policy Modifications
The Company reserves the right to amend, revise, modify, or update this Policy at any time.
Any changes shall become effective upon publication on the Platform unless otherwise stated.
Continued use of the Platform following publication of any revised Policy shall constitute acceptance of the revised Policy.
18. Contact Information
Presstige LLC
Operator of FanzCentral
Email: complaints@fanzcentral.com
Website: https://fanzcentral.com