Complaints and Content Removal Policy and Procedures


General Statement

 RiotModels, as a service provider:

  • is committed to providing the highest standard of quality services to service's Users;
  • will take seriously any concern or complaint and will look into it promptly, for resolution as quickly as possible;
  • recognizes that all service's Users:
    • have the right to raise concerns or complaints about our services;
    • have the right to access clear information on how to voice complaints and concerns.
  • the complaints procedure is open to all Users, persons affected by Content published on the Platform, and anyone acting on their behalf;
  • will deal with complaints in line with RiotModel's Terms of Service, Privacy Policy, and other policies;
  • will keep a register of all complaints, which will be reviewed regularly by the Board of Trustees;
  • the complaints procedure will be part of the process of monitoring the quality, effectiveness, and non-discriminatory nature of its services. 


The objectives of RiotModels complaints policy and procedures are to:

  • Ensure everyone knows how to make a complaint and how a complaint will be handled;
  • Ensure that complaints are dealt with consistently, fairly, and sensitively within clear time frames;
  • Provide individuals with a fair and effective way to complain about our work;
  • Ensure that complaints are monitored to improve our services.

 

RiotModels will ensure that we:

  • Listen carefully to complaints and treat complaints as confidential, where possible;
  • Record, store and manage all complaints accurately and in accordance with the data protection guidelines;
  • Investigate the complaint fully, objectively, and within the stated time frame;
  • Notify the complainant of the results of the investigation and any right of appeal;
  • If possible, inform the complainant of any action that will be implemented in order to ensure that there is no re-occurrence;
  • Report on a monthly basis to the concerned third parties the number of complaints received the outcomes and any actions taken. 

Definition of a complaint

 A complaint is any expression of dissatisfaction or report of potentially illegal, prohibited, non-consensual, or otherwise non-compliant Content, whether or not the allegation is ultimately substantiated.

Complaints may concern:

  • RiotModels' services, operations, or treatment of Users;
  • Content that may be illegal or violate the Terms of Service, Prohibited Content Policy, or applicable Content Standards;
  • Content involving minors, human trafficking, exploitation, coercion, or non-consensual sexual activity;
  • Unauthorized publication or distribution of a person's image, likeness, or intimate Content;
  • Copyright infringement, impersonation, or other violations of applicable rights;
  • The validity or absence of consent from any person depicted in Content.


Any person, including someone depicted in Content who is not a registered RiotModels User, may submit a complaint or request Content removal.

All complaints will be reviewed objectively and resolved in accordance with the procedures described below. 


Concern or Complaint

It is important to establish the difference between a concern and a complaint. Taking informal concerns seriously at the earliest stage will reduce the likelihood of their developing into formal complaints.

If you have any concerns about our work please communicate via support [at] riotmodels [dot] com as soon as possible, so we can quickly understand your concerns and try to put things right.

If you are not happy with the response to your concern and/or you want to make a formal complaint please follow the procedure below. 

Complaints concerning potentially illegal, prohibited, or non-consensual Content may be submitted directly through the formal complaint procedure without first raising an informal concern. Content involving suspected minors, human trafficking, exploitation, or other urgent safety issues will be referred for immediate review.


Complaints Procedure

RiotModels aims to settle all complaints quickly and satisfactorily to all parties involved. The complaint may be resolved quickly by way of an apology or by an acceptable explanation, exchanged between the Model and the Subscribers involved in the complaint.

There are three stages to the complaint’s procedure:

  • Stage One – Complaint
  • Stage Two – Investigation
  • Stage Three – Appeal 

Stage One: Complaint

Any person may submit a complaint by writing to support [at] riotmodels [dot] com or using the Report Content functionality available on the Platform.

A complaint should include, where reasonably possible:

  • The complainant's name and contact information;
  • A link to or sufficient identification of the reported Content or account;
  • A description of the alleged violation or concern;
  • Any relevant supporting information;
  • The action or resolution requested.


Anonymous complaints will also be accepted and reviewed, although the absence of contact information or supporting evidence may limit the investigation.

A person requesting the removal of Content depicting them may be asked to provide information reasonably necessary to establish their identity or authority to act. Such information will be handled confidentially.

Upon receipt, each complaint will be allocated a reference number and recorded in the complaints register.

An acknowledgment will normally be provided within one (1) business day of receipt.

All complaints concerning illegal or potentially prohibited Content will be reviewed and resolved within five (5) business days of receipt.

Complaints involving urgent safety concerns will be escalated for immediate review. 

Stage Two: Investigation

Complaints will be investigated by authorized RiotModels personnel, including the Trust & Safety Team where Content-related concerns are involved.

All reported complaints will be reviewed and resolved within five (5) business days of receipt.

Complaints involving potentially illegal Content, minors, human trafficking, sexual exploitation, non-consensual intimate Content, or other serious safety concerns will be prioritized for immediate review.

During an investigation, RiotModels may temporarily restrict access to the reported Content or suspend related account activities where necessary.

Depending on the nature of the complaint, the investigation may include reviewing the reported Content, associated account information, Content history, performer identity and age verification records, consent documentation, and other relevant evidence.

Where a complaint concerns a person depicted in Content, RiotModels will determine whether valid consent was provided for the creation, publication, distribution, and monetization of that Content.

If the investigation determines that consent was not given or is void under applicable law, the affected Content will be removed.

Possible investigation outcomes include:

  • Dismissal of the complaint where no violation is established;
  • Removal or restriction of the reported Content;
  • Continued restriction of Content pending required corrective action;
  • Requesting additional identity, age, or consent verification;
  • Restoration of Content where appropriate;
  • Suspension of publication or monetization privileges;
  • Suspension or termination of the responsible account;
  • Reporting suspected illegal activity to the appropriate authorities.


The complainant will receive written confirmation of the investigation outcome, subject to applicable privacy and confidentiality requirements.

Where further information is unavailable or a material safety concern remains unresolved, RiotModels may maintain protective restrictions and take an appropriate enforcement decision within the five-business-day resolution period. Any subsequent investigation or appeal will be tracked separately.

All findings, decisions, enforcement actions, and relevant dates will be recorded in the complaints register.

A person dissatisfied with the investigation outcome may appeal under Stage Three. 

Stage Three: Appeal

If a complainant or another directly affected person is dissatisfied with the outcome of an investigation, they may appeal the decision within fourteen (14) working days of receiving the outcome.

Appeals should be submitted to support [at] riotmodels [dot] com with the subject line "Content Removal Appeal" or "Complaint Appeal," as appropriate.

The appeal should identify the original complaint, the decision being challenged, and the reasons for requesting reconsideration.

Appeals will be reviewed by Operations Management or another authorized reviewer who was not responsible for the original decision, where practicable.


Anonymous complaints

Complaints received anonymously will be recorded and considered, but action may be limited if further information is required to ensure a full and fair investigation. 


Data protection

To process a complaint RiotModels will hold personal data about the complainant, which the individual provides, and which other people give in response to the complaint. We will hold this data securely and only use it to address the complaint. 

The identity of the person making the complaint will only be known to those who need to consider the complaint and will not be revealed to other people or made public. 

However, it may not be possible to preserve confidentiality in some circumstances, for example, where relevant legislation is applied or allegations are made which involve the conduct of third parties.

RiotModels will normally destroy complaints files in a secure manner six (6) years after the complaint has been closed. 


Monitoring

Complaints are an important tool that, alongside data provided by other surveys, feedbacks, and focus groups, will allow us to learn about the services we provide. They provide a useful source of information about how individuals see our services and how we are serving them. To ensure we can learn from complaints the following data will be collected:

  • Name of the complainer;
  • Complainer's contact information;
  • Date of complaint; 
  • Nature of complaint; 
  • Date of response;
  • Action(s) taken/recommendations made in response to the complaint.


Complaint's information will be considered on a regular basis by the Management Team and reported annually to the RiotModels' Board of Trustees. Wherever possible the data will be used to improve and develop the service.