Content Monitoring Policy

On gingr.ch, what is reviewed and under which rules is made visible. This policy describes how content on the platform is reviewed, which content is prohibited and how we respond to violations.

In addition, the Anti-Trafficking Policy, the Verification Policy and the Privacy Policy apply.

Scope

This policy applies to all content on gingr.ch:

• escort profiles (texts, images, videos, verification information shown)
• content behind paywalled areas
• reviews and ratings
• chat communication
• any media submitted by users or partners

Sensitive data such as KYC information, health data, payment data or identity documents are never displayed publicly.

Legal basis

Swiss law applies, in particular the Swiss Criminal Code (including Art. 182 SCC on human trafficking, Art. 197 SCC on hard pornography, including the depiction of minors), the Federal Act on Data Protection (FADP) and the Copyright Act (CopA).

Where applicable, the EU General Data Protection Regulation (GDPR) as well as relevant international conventions for the protection against exploitation and human trafficking also apply.

Prohibited content

The following content is strictly prohibited on gingr.ch and will be removed:

• human trafficking, forced prostitution, exploitation or any form of coercion
• any sexual acts involving minors (under 18 years)
• content that sexualises persons who appear or seem to be minors
• non-consensual sexual content, covert recordings, revenge porn or content without the informed consent of all persons involved
• depictions of violence, threats, unconscious or heavily impaired persons
• sexual content involving animals, incest or extreme fetish content in breach of Swiss law
• depiction of illegal substances or criminal activities
• pornographic material in breach of Swiss criminal law or international treaties
• disclosure of other users' personal data such as name, address, phone number, bank details or KYC information
• escort contact details outside the dedicated profile fields
• references to external payment channels that circumvent the booking process
• hate speech, discrimination, extremist symbols or violations of third parties' personality rights
• third-party copyrighted content without the right to use it

Zero tolerance applies to child sexual abuse material (CSAM). Every identified case is suspended immediately and reported to the competent authorities in accordance with the Anti-Trafficking Policy.

Review of profile texts

All texts on an escort profile are reviewed manually before publication. The review covers, among other things:

• compliance with platform terminology (escort, not other terms)
• no contact data (email, phone, external messengers, social media handles) in the free profile text
• no references to external payment channels or circumvention of Secure Booking
• no statements that suggest coercion, dependency or control by third parties
• no discriminatory, degrading or racist wording
• prices, services and availability only in the platform fields provided for that purpose

Review of images and videos

Profile images and profile videos are reviewed manually before publication. In particular, the review covers:

• match of the depicted person with the KYC-verified profile (precondition for the Content Verified label)
• no depiction of minors, also not in the background
• no depiction of third parties without clear consent
• no copyrighted stock images, film stills or third-party content
• no trademarks, logos or protected symbols of third parties
• no deepfakes or AI-generated depictions simulating a real person
• no depictions of violence or content in breach of Swiss criminal law

Content behind paywalled areas

Content that is only visible after unlocking is subject to the same rules as public content. It is reviewed through automated checks and targeted manual spot checks.

Spot checks are risk-based and more frequent for new profiles and profiles with complaints.

Reviews and ratings

Ratings originate exclusively from bookings actually completed via the platform. They are moderated before being published.

Ratings are removed if they:

• disclose personal contact data
• contain discriminatory, degrading or racist statements
• contain explicitly pornographic descriptions that go beyond what is objectively appropriate
• contain manifestly false or defamatory claims
• originate from persons who were not involved in the booking

Chat communication

gingr.ch uses automated tools in chat that review messages in real time for defined risk signals before they are delivered to the recipient.

The review covers, for example, indications of harassment, self-harm, fraud patterns and the exchange of personal contact details (phone numbers, external links).

Depending on the category, a message may be automatically flagged, masked or removed. Links are removed, phone numbers are masked.

A content review by the Safety team takes place if a message is reported or if an automated risk signal has been triggered. The private content of a conversation is not read beyond that.

In the event of a reasonable suspicion of human trafficking, exploitation or CSAM, chat content is preserved as evidence and, where appropriate, transmitted to the authorities, as described in the Anti-Trafficking Policy.

Automated review tools

In addition to manual moderation, gingr.ch uses automated tools. They can, among other things, detect:

• known illegal image hashes, in particular from CSAM databases, once the corresponding integration has been completed
• suspicious patterns in booking and registration data
• repeated reports or behavioural indicators of exploitation

Automated tools do not replace human review. Every suspension or removal is based on a human decision, unless it is an immediate, predefined protective measure (for example the masking of phone numbers or the removal of links in chat).

Reporting channels

Violations can be reported at any time, anonymously or with identification:

• report form directly on the profile
• live chat (24/7) on the platform
• email to abuse@gingr.ch
• Help Center

Reports involving suspected human trafficking, exploitation or minors are handled with the highest priority.

Response and escalation levels

Where a violation is established, gingr.ch decides based on severity, recurrence and risk situation:

• warning and removal of the content concerned
• feature restriction (e.g. no booking, no chat)
• temporary account suspension
• permanent account closure
• reporting to the competent authorities

In case of suspicion of trafficking, exploitation, involvement of minors or organised crime, the case is escalated and handled in cooperation with the competent Swiss authorities. Details are set out in the Anti-Trafficking Policy.

Appeal procedure

Affected persons may appeal against moderation decisions.

Appeals are submitted in writing to support@gingr.ch or via the contact function within the account. The appeal procedure comprises:

• confirmation of receipt by gingr.ch
• review by a second, independent person from the Safety team
• written reasoning of the decision
• in case of a rejected appeal, the possibility of a further review by the Compliance lead

No appeal is possible in cases of legally mandatory suspension, in particular for CSAM, confirmed forgery of identity documents or official orders.

Human review of automated decisions

If a restriction or suspension is primarily based on automated signals, the affected person may request human review. Requests are sent to support@gingr.ch and handled in accordance with the appeal procedure.

Training and awareness

All staff in Moderation, Support, Product and Compliance receive regular training on:

• Swiss and EU law on adult content
• recognition of indicators of trafficking and exploitation
• data protection, data security and user rights
• internal escalation and reporting processes

Where appropriate, workshops are conducted with NGOs or specialist bodies.

Cooperation with authorities and specialist bodies

gingr.ch cooperates, where legally required or for good cause, with Swiss law enforcement authorities, international investigative bodies, recognised NGOs and victim-support organisations.

Data is shared only where this is legally mandatory or serves the protection of potential victims. Details are set out in the Anti-Trafficking Policy.

Confidentiality and data protection

All moderation measures are carried out in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).

• Only authorised personnel have access to moderation tools.
• KYC data is processed externally and not shared with other users. Every person has, under FADP and GDPR, the right of access to their own data.
• Sensitive data is never displayed publicly.
• Moderation logs remain confidential unless a statutory disclosure obligation applies.

Detailed information is provided in the Privacy Policy.

Responsibility

Responsibility for this policy rests with:

• the Board of Directors of G-IT AG (governance)
• the Head of Security (operational oversight and enforcement)
• the Compliance Officer (legal standards and reporting)

Regular internal reports document the number of removed content items, categories of violations, escalations to authorities as well as improvement measures.

Review and updates

This policy is reviewed at least once a year, upon the introduction of new platform features, upon changes to the legal framework or upon new insights from moderation practice.

Contact

For questions about this policy:

Reports: abuse@gingr.ch
Support: support@gingr.ch
Help Center: gingr.ch/en/info

Publisher: Safety & Compliance Unit, G-IT AG
Version 1.4, as of April 2026