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CONTENT MODERATION POLICY

This Content Moderation Policy (“Policy”) establishes the legal framework governing the monitoring, review, restriction, removal, enforcement, and reporting of content, data, and user interactions on the platform operated by NTEC Limited (“Company”, “We”, “Us”).

This Policy forms an integral and inseparable part of the platform’s legal framework and shall be read together with:

By accessing, posting, transmitting, storing, sharing, or otherwise making content available through the platform, you acknowledge that you have read, understood, and agreed to be bound by this Policy.

1. Purpose and Scope

1.1 Purpose

This Policy is intended to:

  • maintain the safety, integrity, and proper functioning of the platform;
  • protect users from illegal, harmful, abusive, fraudulent, or misleading content;
  • support compliance with legal, regulatory, AML/CFT, data protection, and risk management obligations;
  • establish a lawful and transparent basis for content moderation and enforcement actions.

1.2 Scope of Application

This Policy applies to:

  • all users, whether registered or not;
  • all accounts, profiles, and user identifiers;
  • all content created, uploaded, transmitted, displayed, or otherwise made available through the platform;
  • all user interactions occurring within systems, features, or environments controlled by the Company.

1.3 Types of Content Covered

Content subject to moderation includes, without limitation:

  • chat messages, posts, comments, and replies;
  • usernames, avatars, status messages, and profile information;
  • images, videos, audio files, hyperlinks, QR codes, embedded content;
  • documents, promotional materials, and commercial content;
  • content generated via automated tools or assisted technologies;
  • any other form of digital expression transmitted or displayed via the platform.

1.4 Private Communications

While private communications are not routinely monitored for public display purposes, you acknowledge and agree that the Company may access, review, retain, or process such communications where reasonably necessary, including but not limited to:

  • investigating user reports or complaints;
  • detecting fraud, abuse, threats, or unlawful conduct;
  • enforcing Terms of Use or internal policies;
  • complying with legal or regulatory obligations.

2. Legal Basis for Moderation

2.1 Contractual Basis

Moderation is carried out under the contractual relationship established by the Terms of Use. Users are required to comply with all applicable rules, conditions, and policies governing platform usage.

2.2 Legal and Regulatory Compliance

The Company may moderate content to comply with applicable laws and regulatory obligations, including but not limited to:

  • anti-money laundering and counter-terrorism financing (AML/CFT);
  • fraud prevention and system abuse detection;
  • data protection and user safety requirements;
  • protection of minors and prevention of prohibited content;
  • lawful cooperation with competent authorities.

2.3 Legitimate Interests

The Company has a legitimate interest in maintaining a platform that is:

  • secure and stable;
  • free from misuse, exploitation, or unlawful activity;
  • protective of user rights, data, and system integrity.

3. Moderation Principles

3.1 Fairness

The Company applies moderation standards consistently across users, without preferential treatment or discrimination.

3.2 Content and Behavior-Based Assessment

Moderation decisions are based on observable content, context, behavioral patterns, and risk indicators. The Company is not required to wait for actual harm before taking action.

3.3 Proportionality

Enforcement measures may consider:

  • severity of the violation;
  • frequency and repetition;
  • user history;
  • risk to platform integrity, users, or compliance obligations.

However, immediate and strict measures may be applied where necessary.

3.4 Confidentiality and Limited Disclosure

The Company may retain internal records of moderation decisions but is not obligated to disclose:

  • internal detection methods;
  • moderation criteria;
  • reporting sources;
  • or sensitive evidence.

3.5 Priority of Safety and Compliance

Where user rights conflict with legal obligations, system integrity, or user protection, the Company may prioritize safety and compliance.

4. Prohibited Content and Conduct

Without limitation, the following are strictly prohibited:

4.1 Illegal Content

Content that:

  • violates applicable laws or regulations;
  • promotes or facilitates criminal activity;
  • relates to fraud, money laundering, or financial crime.

4.2 Abusive or Harmful Content

Including:

  • harassment, threats, or intimidation;
  • hate speech or discriminatory content;
  • content causing harm to individuals or groups.

4.3 Sensitive or Restricted Content

Including:

  • pornographic or sexually explicit material;
  • any content involving minors (zero tolerance);
  • violent or extremist content;
  • malicious software or harmful code.

4.4 Fraudulent or Deceptive Content

Including:

  • impersonation of staff, users, or third parties;
  • phishing or attempts to collect sensitive information;
  • distribution of malicious links.

4.5 Spam and Unauthorized Promotion

Including:

  • unsolicited advertising;
  • repeated or bulk messaging;
  • unauthorized commercial content.

4.6 Privacy Violations

Including:

  • disclosure of personal or financial data without authorization;
  • solicitation of sensitive user information.

4.7 Intellectual Property Violations

Including:

  • unauthorized use of copyrighted materials;
  • infringement of trademarks or proprietary content.

4.8 Circumvention of Moderation

Including:

  • attempts to bypass filters or detection systems;
  • re-posting removed content;
  • using alternative accounts to evade enforcement.

5. Monitoring and Moderation Mechanisms

5.1 Automated Systems

The Company may use:

  • AI-based detection tools;
  • keyword filtering;
  • behavioral monitoring systems.

These systems may:

  • block or restrict content;
  • flag accounts;
  • trigger enforcement actions.

5.2 Human Review

Content may be reviewed by moderation, compliance, or risk teams based on:

  • system flags;
  • user reports;
  • internal investigations.

5.3 User Reporting

Users may report violations. However:

  • reports do not guarantee action;
  • final decisions remain at the Company’s discretion.

6. Enforcement and Sanctions

The Company may apply, without limitation:

  • content removal or restriction;
  • warnings (optional);
  • feature limitations;
  • temporary or permanent suspension;
  • account termination;
  • reporting to authorities.

Enforcement may be applied immediately and, where appropriate, retroactively.

7. Company Rights and Discretion

The Company retains sole and absolute discretion to:

  • moderate content;
  • suspend or terminate accounts;
  • take enforcement actions without prior notice;
  • refuse explanations where disclosure may compromise compliance or security.

All internal decisions are final, subject only to applicable law.

8. Appeals and Review

Users may submit appeals via support@hitclub.bio.

The Company:

  • may review decisions internally;
  • is not obligated to reverse any decision;
  • may reject appeals without detailed explanation.

9. Data Processing and Retention

Moderation-related data may be:

  • stored and analyzed;
  • retained for compliance, AML, and legal purposes;
  • disclosed to competent authorities where required.

All data processing shall be aligned with the Privacy Policy.

10. Limitation of Liability

The Company:

  • does not pre-approve all user content;
  • is not liable for user-generated content;
  • reserves the right to intervene at any time.

Failure to act does not constitute acceptance or waiver of rights.

11. Effective Date

This Policy shall take effect as of 12/01/2026 (“Effective Date”).

From the Effective Date:

  • this Policy supersedes all prior versions or internal moderation rules;
  • continued use of the Services constitutes acceptance of this Policy;
  • the Company may enforce this Policy immediately, including for compliance, security, or risk management purposes.

Where updates are made:

  • a revised effective date shall be indicated;
  • continued use after such date constitutes legally binding acceptance.

The Company may retain previous versions for audit, compliance, or regulatory purposes.

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