Human Rights Policy

1. Our Commitment

AlemX Inc. ("AlemX") is committed to respecting human rights across our products, our operations, and our business relationships. This Policy sets out (a) the international standards that frame our commitment, (b) the salient human-rights risks we have identified for an early-stage social user-generated-content ("UGC") platform, (c) how we govern this commitment internally, and (d) how affected users and third parties can raise human-rights concerns with us.

We recognize that our authority over speech, identity, and access on the AlemX platform carries human-rights consequences for the people who use AlemX. We approach that authority with the care that recognition demands.

2. International Standards We Follow

This Policy is grounded in the following international instruments:

• The UN Guiding Principles on Business and Human Rights ("UNGPs"), endorsed by the UN Human Rights Council in 2011. The UNGPs articulate the corporate responsibility to respect human rights — independent of, and additional to, the state duty to protect them.
• The Universal Declaration of Human Rights ("UDHR"), 1948.
• The International Covenant on Civil and Political Rights ("ICCPR"), 1966, particularly Article 17 (privacy), Article 19 (freedom of opinion and expression), Article 20 (prohibition of war propaganda and incitement), and Article 26 (equal protection).
• The International Covenant on Economic, Social and Cultural Rights ("ICESCR"), 1966.
• The UN Convention on the Rights of the Child ("CRC"), 1989, and General Comment No. 25 (2021) on children's rights in relation to the digital environment.
• The UN Convention on the Elimination of All Forms of Discrimination Against Women ("CEDAW"), 1979.

We treat these instruments as the floor — not the ceiling — of our human-rights commitment. Where domestic law in a jurisdiction where we operate falls below the standard set by these instruments, we will seek to honor the international standard to the maximum extent legally possible, and we will be transparent about any divergence.

3. Scope

This Policy applies to:

• The AlemX platform, including all surfaces (chat, posts, media, profiles, search, recommendations, advertising once introduced).
• All AlemX users, worldwide, regardless of their country of residence.
• All AlemX personnel, including employees, contractors, and outside counsel acting on AlemX's behalf.
• AlemX's business relationships, including vendors, partners, and integrated service providers, to the extent of AlemX's leverage over their human-rights conduct.

4. Salient Human-Rights Risks We Have Identified

Following the UNGPs' guidance on prioritization, we identify the human rights most at risk of severe negative impact through AlemX's operations. As an early-stage social UGC platform, our salient risks are:

4.1 Privacy (ICCPR Article 17)

Risk of disproportionate collection, retention, sharing, or exposure of user data — including in response to government requests, vendor sub-processing, security incidents, or product features that inadvertently expose private information.

Our response. Privacy-by-design principles in product development; minimum-necessary data collection; the disclosure standards set out in the AlemX Law Enforcement Guidelines (§3, §6); the SOC 2 audit currently in progress; the AlemX Privacy Policy (separate document).

4.2 Freedom of expression (ICCPR Article 19)

Risk of over-enforcement (removing speech that users have a right to make) and under-enforcement (failing to remove speech that genuinely violates the rights of others). Risk of inconsistent enforcement that disproportionately affects particular communities.

Our response. Published Community Guidelines with category definitions; user appeals mechanism per §6 below; aggregate reporting in the AlemX Transparency Report; periodic external review of enforcement consistency.

4.3 Child safety (CRC + UN General Comment No. 25)

Risk of children being exposed to abuse material, contacted by adults seeking to exploit them, or otherwise harmed via the AlemX platform.

Our response. Use of Microsoft PhotoDNA for CSAM hash matching; intended NCMEC ESP registration for CyberTipline reporting; minimum-age enforcement; reporting and appeal flows tailored to under-18 users; the StopNCII partnership once activated.

4.4 Freedom from violence and incitement (ICCPR Article 20)

Risk that terrorist or violent extremist actors exploit the AlemX platform to spread content, recruit, coordinate, or incite violence.

Our response. Explicit ToS prohibition (see Terms of Service); intended GIFCT membership and participation in the GIFCT Hash-Sharing Database; the human-rights safeguards required by GIFCT membership, including this Policy.

4.5 Non-discrimination and equal protection (UDHR Article 2; ICCPR Article 26; CEDAW)

Risk that AlemX's policies or their enforcement disproportionately affect users on protected grounds — including gender, ethnicity, language, religion, political opinion, national origin, sexual orientation, or disability.

Our response. Category-level Transparency Report breakdowns to make disparate enforcement visible; periodic internal review of moderation decisions for systematic bias; engagement with civil-society stakeholders representing affected groups (see Civil Society Engagement Roadmap).

4.6 Right to remedy (UNGPs Pillar III; UDHR Article 8)

Risk that users harmed by AlemX moderation decisions, account actions, or data-handling have no effective way to seek correction.

Our response. The user-appeals mechanism described in §6; the grievance channel for human-rights concerns described in §7; AlemX's commitment to reverse erroneous decisions promptly and publicly account for reversal rates in the Transparency Report.

5. Governance

Accountability. The Compliance Coordinator is the senior individual at AlemX responsible for this Policy's implementation. The CEO is the executive accountable for this Policy.

Integration. Human-rights considerations are part of (a) product development reviews for features that materially change user-data handling or moderation; (b) vendor risk assessments (per the AlemX Vendor Risk Register); (c) legal-review decisions concerning Government Requests (per the AlemX Law Enforcement Guidelines §5(5)).

Review. This Policy is reviewed at least annually by the Compliance Coordinator and updated as the salient risk picture changes — for example, as AlemX scales, as new features are launched, or as new business relationships are established. Material changes require CEO approval.

Training. All AlemX personnel who make moderation, legal-disclosure, or product-design decisions affecting users receive periodic training on this Policy. New personnel receive an introduction to this Policy as part of onboarding.

6. Transparency

We commit to publishing a periodic Transparency Report covering Government Requests, content-moderation actions, account-level actions, user appeals, and privacy/data-subject requests. Cadence, categories, and methodology are defined in the AlemX Transparency Report Policy, which is incorporated here by reference.

The Transparency Report is the principal artifact through which AlemX accounts publicly for the enforcement of its Community Guidelines, the handling of Government Requests, and the operation of the appeals mechanism. We treat the Report as a human-rights instrument as well as a compliance one.

7. Grievance Mechanism

Users, civil-society organizations, researchers, and members of the general public can raise human-rights concerns with AlemX through the following channels:

• User appeals (decisions affecting your own account or content). Submitted through the in-app appeals flow at the time of the moderation decision, or by email to appeals@alemx.com. Median time to first response: target seven (7) calendar days.
• Human-rights inquiries (third-party concerns, civil-society outreach, researcher questions). Email human-rights@alemx.com. Median time to acknowledgment: target seven (7) calendar days; substantive response according to the complexity of the inquiry.
• Confidential or whistleblower concerns about AlemX's own human-rights conduct. Email compliance@alemx.com, with the subject line beginning [CONFIDENTIAL HR]. AlemX will not retaliate against any person who raises a good-faith concern through this channel.

8. Working With Our Partners

AlemX expects the vendors, partners, and integrated service providers we work with to respect human rights consistent with this Policy. Where our leverage allows, we will:

• Reference this Policy in new commercial agreements where appropriate.
• Conduct human-rights-informed risk assessments of vendors handling sensitive user data, in addition to security and privacy assessments.
• Engage with partners constructively where their conduct raises human-rights concerns, and consider termination of the relationship as a remedy of last resort.

9. Limitations and Honesty

AlemX is a small, pre-launch company. We do not yet have the resources of a mature platform; some of the commitments in this Policy describe a direction of travel rather than a state that is fully operational today. Where there is a gap between the standard set out here and our current practice, we will (a) say so candidly in the Transparency Report, (b) describe what we are doing to close the gap, and (c) accept feedback from external stakeholders on whether the pace of progress is acceptable.

We would rather publish an honest policy with disclosed gaps than an aspirational policy that overstates our maturity.