Purpose
This Content Monitoring Policy outlines the safety, compliance, and legal standards governing all content on gingr.ch. It is designed to prevent illegal activities — including human trafficking and exploitation — and to ensure that all published content meets Swiss legal requirements and applicable international standards such as the ECHR (EMRK).
This policy applies to all content types on gingr.ch, including:
Escort profiles (texts, images, verification data as displayed)
Paid content uploads (photos, videos, audio)
User reviews and feedback
Booking-related communication when flagged or risk-indicated
Any other media submitted by users or service providers
Public content is limited strictly to what is necessary for bookings and discovery. Sensitive data (KYC, health, payment, identity documentation) is never made public.
1. Scope
This policy applies to all users, escorts, clients, moderators, employees, contractors, and technical systems interacting with content on gingr.ch.
2. Prohibited Content
The following categories of content are strictly prohibited and will be removed immediately:
Human trafficking, coercion, forced labour, pimping, or any form of exploitation
Any sexual activity involving individuals under 18 years old
Content sexualising persons who appear to be under 18 (e.g., apparent minors, roleplay implying minors)
Non-consensual sexual content, hidden recordings, “revenge porn”, or any content created without informed consent
Depictions involving violence, threats, unconscious or heavily intoxicated persons
Bestiality, incest, extreme fetish content prohibited under Swiss law
Illegal substances or depiction of criminal activities
Pornographic material that violates Swiss criminal law or international treaties
Any disclosure of personal data of other users (names, addresses, phone numbers, bank details, KYC information)
Any content violating Swiss law or applicable international treaties (including EMRK)
The platform has zero tolerance for CSAM (Child Sexual Abuse Material). Any detected case will be immediately escalated to law enforcement.
3. Content Submission and Verification
3.1 User & Service Provider Verification
All escorts must complete full KYC/ID verification before any content can be published.
Clients may access gingr.ch under different verification tiers (email, phone, optional KYC). Certain features — such as "Pay on Invoice" — require KYC.
KYC is conducted via our external provider Dataspike. Data is securely processed and stored in the EU/EEA. KYC data is never shared with escorts or clients.
3.2 Content Review
All escort profile images and texts undergo manual review before publishing.
Paid content uploads (images, videos, audio) are reviewed using a combination of automated checks and targeted manual moderation.
Randomised post-publication audits ensure continued compliance.
4. Monitoring and Auditing
4.1 Automated Monitoring
The platform uses automated tools to assist in detecting:
Known illegal image hashes (e.g., CSAM databases)
Suspicious keywords or booking patterns
Repeated reports or behavioural indicators of trafficking
Automated tools do not replace human judgement but support faster identification of risk.
4.2 Human Audits
The moderation team conducts regular audits of all content categories.
Audit logs include timestamp, moderator identity, action taken, and reason.
Where legally required, evidence is retained for law enforcement.
4.3 Reporting Channels
Users can report content or behaviour via:
In-booking report function
Live chat with our support team
Help Center at gingr.ch/info/help
Reports involving potential exploitation or minors are prioritised.
5. Response and Enforcement
5.1 Immediate Action
If content violates this policy, Gingr will immediately:
Remove the content
Restrict or freeze the associated account
Review connected accounts and activity
5.2 Escalation Path
Depending on severity:
Warning and content removal
Temporary restrictions
Temporary suspension
Permanent account termination
5.3 Reporting to Authorities
Any reasonable suspicion of:
Human trafficking
Exploitation
Involvement of minors
Criminal operations
will be escalated to Swiss law enforcement and, when relevant, international authorities.
5.4 Appeals
Users may appeal moderation decisions. Appeals are reviewed by a second moderator or a senior compliance officer.
6. Training and Awareness
All Gingr staff involved in moderation, support, product, or compliance receive regular training on:
Swiss and EU laws on adult content
Identification of trafficking indicators
Privacy, data protection, and user rights
Internal escalation procedures
Workshops with NGOs or specialised anti-trafficking experts may be conducted as needed.
7. Collaboration with Authorities & NGOs
Gingr cooperates fully with:
Swiss law enforcement
International authorities where required
Recognised NGOs and victim-support organisations
Information is shared only when legally mandated or necessary to protect potential victims.
8. Review and Updates
This policy is reviewed:
At least annually
When new platform features are introduced (e.g., new media formats, payout options)
When regulatory frameworks change
Updates may be conducted in consultation with legal experts, compliance bodies, or industry groups.
9. Confidentiality & Data Protection
All monitoring activity complies with Swiss Data Protection Law and, where applicable, the GDPR.
Only necessary staff have access to moderation tools
KYC information is processed externally and not accessible to escorts
Sensitive data is never displayed publicly
Moderation logs are kept confidential unless disclosure is required by law
For full details, users may refer to the Gingr Privacy Policy.
10. Accountability
Responsibility for this policy lies with:
Management Board of G-IT AG (governance)
Head of Security (operational oversight & enforcement)
Compliance Officer (legal standards & reporting)
The team provides periodic internal reports including:
Number of removed items
Categories of violations
Escalations to authorities
Recommendations for improved safety and monitoring
Contact Information
For questions regarding this policy, please contact:
Gingr Compliance Team – [email protected]
Version 1.2 — Effective Date: 8 December 2025