Acceptable use policy

Status: DRAFT — FOR LEGAL REVIEW
Version: 0.2
Date: 2026-10-18
Owner: Head of Trust & Safety (to be appointed)
Jurisdiction: Canada (operating company); EU users served under the DSA and GDPR; market neutral
Applicable law: Criminal Code of Canada, Personal Information Protection and Electronic Documents Act (PIPEDA), Digital Services Act (Regulation (EU) 2022/2065) and GDPR for EU users, UK Online Safety Act 2023 (for UK users)
Reviewed by counsel: [pending]
Next review: Prior to platform launch, then annually

This document is a draft prepared for review by qualified legal counsel. It forms part of Aurora's contractual terms and interacts with the Terms of Service, Content Moderation Policy, and DSA Notice and Action Procedure. It is required by DSA Art. 14 (terms of service clarity).

1. Purpose and Scope

This Acceptable Use Policy (the "AUP") sets the baseline rules of conduct and content on Aurora. It applies to everyone who accesses or uses the Platform, including:

• Providers — independent adult companions who publish a profile (their advertisement) on Aurora and are responsible for its content.
• Agency managers and provider-delegates — as of Phase 2.
• Members (also called clients) — adults browsing profiles and, where the feature is available, messaging providers and keeping a screening profile.
• Visitors — unauthenticated users viewing public pages.
• Aurora staff and contractors — in addition to internal conduct policies.
• Third parties — including trusted flaggers and law enforcement, when they interact with the Platform through public channels.

The AUP is incorporated by reference into the Terms of Service. Violation can result in removal of content, suspension, termination of your account, and — where the violation involves illegal conduct — referral to law enforcement.

2. Eligibility

You must satisfy all of the following to use Aurora:

1. Age. You are at least 18 years old, or 21 where that is the minimum applicable age in your jurisdiction (for example, certain US states in Phase 4+). Age is verified at signup using government ID and liveness (Didit) for providers and for Gold-tier members, and via age-attestation or Didit for other paying members. In the United Kingdom, age assurance is performed under the Online Safety Act 2023 using an approved provider.
2. Legal capacity. You have the legal capacity to enter a binding contract in your jurisdiction.
3. Not under sanction. You are not on a Canadian, EU, UN, or OFAC sanctions list, and you are not a resident of a sanctioned territory.
4. Compliance with local sex-work law. Providers using Aurora must be operating lawfully in the jurisdiction in which services are offered and performed, and must be legally permitted to advertise those services there. Providers are the advertisers and are responsible for their advertisements. Providers in jurisdictions where adult companion services, or the advertising of them, are illegal may not use Aurora to advertise those services. Aurora's own position under sections 286.2 and 286.4 of the Criminal Code of Canada is under review by Aurora's Canadian counsel.
5. One account per natural person per user type. Duplicate provider accounts or duplicate client accounts are not allowed. A natural person may hold both a provider and a client account, subject to the rules of each.
6. Not a banned user. You are not a person whose Aurora account has previously been permanently terminated for a violation of this AUP or the Terms of Service, unless Aurora has expressly reinstated you in writing.

3. Prohibited Content

The following content is prohibited on Aurora in any form — profile text, photos, videos, messages, reports, support requests, or metadata. Categories marked zero tolerance result in immediate permanent termination and mandatory referral to law enforcement without opportunity to appeal.

3.1 Zero Tolerance

• Child sexual abuse material (CSAM) — any visual depiction, real or AI-generated, of a minor (under 18) in a sexual context. Aurora runs PhotoDNA hash matching on every media upload. Confirmed CSAM is reported to NCMEC (via the CyberTipline) and to the Canadian Centre for Child Protection (Cybertip.ca) and the competent police service. Prohibited under the Criminal Code of Canada.
• Any depiction or description of a minor in a sexual, suggestive, or exploitative context, including requests for services involving minors, references to age play with minors, or content that sexualizes minors.
• Human-trafficking content — content suggesting coercion, control by a third party, restriction of movement, or exploitation, consistent with ILO/UNODC indicator frameworks. Reported to the competent police service. Prohibited under the Criminal Code of Canada.
• Non-consensual intimate imagery (NCII) — sexually explicit images or videos of an identifiable person shared without the depicted person's knowing, freely-given consent. Prohibited under the Criminal Code of Canada.
• Bestiality and necrophilia — or depictions of such acts. Prohibited under the Criminal Code of Canada.
• Depictions of real, non-consensual violence, torture, or sexual assault.

3.2 Prohibited Content (Removal + Account Action)

• Weapons and illegal substances. Advertising, sale, or promotion of firearms, explosives, or controlled drugs, including references to "party and play" in connection with illicit drugs as a service offering.
• Fraud and scams. Fake profiles, bait-and-switch profiles (the content does not represent the actual person offering services), advance-fee fraud, phishing, fake reviews or testimonials, deceptive rates.
• Impersonation. Using another person's photos, name, identity, credentials, or likeness. Use of stolen photos is prohibited even if the provider has altered them.
• Doxxing and privacy violations. Posting another person's real name, home address, workplace, phone number, ID number, or other identifying information without that person's consent.
• Hate speech, extremism, and incitement. Content that promotes violence, hatred, or discrimination on the basis of race, ethnicity, national origin, religion, gender, sexual orientation, gender identity, disability, or other protected characteristic.
• Terrorism content. Including content covered by Regulation (EU) 2021/784 on terrorist content online.
• Copyright and trademark infringement. Content that infringes another person's intellectual property rights. See the DMCA / EU Copyright Takedown Procedure (dmca-copyright.md).
• Malware and exploit content. Links, attachments, or code designed to compromise other users' devices or accounts.
• Spam and bulk unsolicited messaging. Including duplicate profiles, SEO manipulation, bot activity, link-farming.
• Illegal services. Offers of services that are illegal in the jurisdiction where the provider is located or where the service would be performed — for example, services offered from a place where adult companion services or their advertising are illegal, or in jurisdictions where Aurora does not accept listings.

4. Prohibited Conduct

The following conduct is prohibited on Aurora regardless of the specific content involved. Aurora takes graduated action based on severity, intent, and history.

• Harassment, stalking, and threats. Targeted abuse, credible threats of violence or outing, repeated unwanted contact, or any conduct that a reasonable person would find intimidating, hostile, or offensive.
• Evasion of bans. Creating new accounts to circumvent a suspension or permanent ban, including using alternative email addresses, phone numbers, identities, or devices.
• Circumventing or attempting to bypass age verification, KYC, liveness checks, sanctions screening, or moderation systems — including by using another person's identity documents, deepfakes, or cooperating with another person to defeat verification.
• Scraping, crawling, and bulk extraction. Automated access to the Platform other than through published APIs with written authorization; scraping profile content, photos, messages, or other user data; training machine-learning models on Aurora content without express written permission.
• Reverse engineering and interference. Probing, scanning, or testing the vulnerability of Aurora systems without authorization (bug bounty participants are authorized within the scope of the Intigriti program); interfering with or disrupting service; bypassing security or access controls.
• Impersonation of Aurora, staff, moderators, or other users.
• Commercial misuse. Using Aurora for any purpose outside its intended function — for example, using profiles as cover for unrelated commerce, MLM recruitment, drop-shipping, or cryptocurrency promotion.
• Recording or capturing other users without consent — including screen-recording messages (Aurora applies screenshot detection on mobile as a deterrent), recording video calls, or photographing sessions.
• Sharing another user's private data obtained through Aurora, including screening documents, identity details, messages, or session notes, outside the shared-blocklist network's opt-in, consented channel.
• Solicitation of illegal services or services with persons known or suspected to be under 18.
• Abuse of reporting and appeals systems. Submitting notices in bad faith, mass-flagging competitors, or repeatedly submitting manifestly unfounded reports is a misuse of DSA Art. 16 and is itself a violation of this AUP.

5. Mandatory Conduct

Users are expected to, and agree to:

• Respect screening requirements. Clients must provide the information providers reasonably request for screening, truthfully. Providers must handle screening data lawfully (GDPR) and delete it when no longer needed.
• Honour your commitments. Any arrangement between a provider and a member is made directly between them; Aurora is not a party to it and does not handle payments between users. Both parties are expected to be truthful about what they have agreed.
• Respect consent. Everything on Aurora operates on the premise of enthusiastic, ongoing, withdrawable consent between adults. Consent to one act is not consent to another; consent to meet is not consent to record, and so on.
• Provide accurate information. Verification data, profile content, and screening submissions must be accurate and kept current. Misrepresentation is a violation.
• Cooperate with moderation. Users must respond to moderation inquiries within a reasonable time and must not obstruct investigations.
• Report violations. If you see content or conduct on Aurora that violates this AUP or the law, report it via the in-product reporting tool, the web form at auroramembers.com/report, or [email protected].
• Comply with local law. Each user is responsible for complying with the law of the jurisdiction in which they are located and in which they operate. Aurora's compliance controls do not relieve users of their own legal obligations.

6. Reporting Violations (DSA Art. 16)

Any person — not only registered users — can report content or conduct they believe violates this AUP or the law. Reporting is governed by Aurora's DSA Notice and Action Procedure (dsa-notice-action.md). Reports can be submitted:

• Via the in-product "Report" button on any profile, media item, or message thread.
• Via the web form at auroramembers.com/report.
• Via email to [email protected].

A valid notice under DSA Art. 16(2) should contain: (a) a reasoned explanation of the alleged illegality, (b) a precise URL or identifier, (c) the reporter's name and email address (unless reporting content that infringes Art. 3 or 4 of Directive 2011/93/EU), and (d) a good-faith statement. See the DSA Notice and Action Procedure for details.

Reports of imminent threats to life should additionally be directed to local emergency services (for example 911 in Canada, 112 in the EU).

7. Enforcement

Aurora enforces this AUP through a graduated set of actions, applied proportionately to the severity and recurrence of the violation. Aurora reserves the right to take any of these actions at its discretion in accordance with applicable law:

Every enforcement decision that restricts a user's visibility, reach, or account is accompanied by a Statement of Reasons under DSA Art. 17, delivered to the affected user, identifying the facts relied on, the legal or contractual basis, and the avenues for redress.

7.1 Appeals

Users can appeal enforcement decisions through:

• Internal complaint-handling system under DSA Art. 20 — free, user-friendly, decided within 14 calendar days by staff not involved in the original decision.
• Out-of-court dispute settlement under DSA Art. 21 — through a certified body of the user's choice.
• Judicial redress — the courts of [Province], Canada have jurisdiction as specified in the Terms of Service, without prejudice to mandatory consumer-protection rights in the user's place of residence (for EU consumers, including Rome I Regulation Art. 6).

Appeals are not available for confirmed CSAM, confirmed trafficking, or confirmed underage-user cases, consistent with DSA Art. 17(3) and Aurora's zero-tolerance policy.

7.2 Account Recovery After a Ban

Account recovery after a permanent ban is limited and, in the case of zero-tolerance violations, unavailable.

• Zero-tolerance violations (Section 3.1): no recovery. A person permanently banned for such a violation cannot return to Aurora under any identity.
• Other permanent terminations: recovery is possible only where the ban is overturned on appeal, under a certified ADR procedure, or by court order.
• Terminations for fraud or payment abuse: recovery requires restitution and a hold period of not less than 12 months.
• Voluntary account deletion: a user who deleted their own account in good standing may return subject to re-verification.

8. Interaction with Other Policies

This AUP is read together with, and cross-refers to:

• Terms of Service (terms-of-service.md)
• Privacy Policy (privacy-policy.md)
• Content Moderation Policy (content-moderation-policy.md)
• DSA Notice and Action Procedure (dsa-notice-action.md)
• DMCA / EU Copyright Takedown Procedure (dmca-copyright.md)
• Law Enforcement Guidelines (law-enforcement-guidelines.md)
• AML/KYC Policy (aml-kyc-policy.md)

In case of inconsistency, the Terms of Service govern, followed by the Content Moderation Policy, then this AUP.

9. Changes

We may update this AUP to reflect changes in law, product, or operating practice. Material changes will be notified at least 30 days in advance via email and in-product notification, unless a shorter period is required by law. Continued use after the effective date constitutes acceptance of the updated AUP.

DRAFT — FOR LEGAL REVIEW. This AUP must be reviewed and approved by qualified legal counsel with expertise in Canadian criminal law (including Criminal Code ss. 286.2 and 286.4), DSA compliance, and the law on advertising adult services before publication.