Transparency Report Cadence Policy

AlemX, Inc. ("AlemX") publishes a periodic Transparency Report so that users, civil society, regulators, and the general public can see how AlemX exercises its policy-enforcement authority over the AlemX platform. This Policy sets out (a) the cadence on which AlemX commits to publish, (b) the categories of activity that the report will cover, (c) the publication channel, and (d) the methodology AlemX will use to compile each report.

1. Purpose

This Policy documents AlemX's commitment to periodic public transparency reporting, including the applicable framework (SOC 2 Type II — CC 2.3, CC 7.5) and compliance with the Global Internet Forum to Counter Terrorism (GIFCT) membership criterion 4, which requires an annual Transparency Report.

2. Cadence

Initial cadence: semi-annual. AlemX commits to publishing a Transparency Report on a semi-annual schedule:

• H1 report: covers 1 January through 30 June; published no later than 30 September of the same year.
• H2 report: covers 1 July through 31 December; published no later than 31 March of the following year.

First report. The first AlemX Transparency Report will cover the period from the AlemX public launch date through the immediately following 30 June or 31 December, whichever comes first. If the public launch precedes a reporting boundary by fewer than ninety (90) days, the first report will roll forward and cover the partial period together with the next full half-year.

Cadence change. AlemX reserves the right to move to a quarterly cadence as data volumes grow. Any change in cadence will be (a) announced in the immediately preceding report, and (b) reflected in a revised version of this Policy.

3. Categories of Activity Reported

Each Transparency Report will include, at minimum, the categories below. Categories are reported in aggregate; AlemX does not publish information that could identify individual users.

3.1 Government and law-enforcement requests

• Total number of Government Requests received (as defined in the AlemX Law Enforcement Guidelines).
• Breakdown by request type: subpoena, court order, search warrant, Emergency Disclosure Request, preservation request.
• Breakdown by requesting jurisdiction (country level).
• Disposition: requests honored in full, honored in part, declined, withdrawn, challenged.
• Volume of user accounts affected.

3.2 Content moderation actions on user-generated content

• Total content items actioned (removed, restricted, age-gated, demoted).
• Breakdown by policy category, including:
  • Child Sexual Abuse Material ("CSAM") — including counts of CyberTipline reports filed with the U.S. National Center for Missing & Exploited Children ("NCMEC") and, once operational, hash matches via Microsoft PhotoDNA.
  • Non-consensual intimate imagery ("NCII") — including, once the StopNCII.org partnership is active, hashes submitted to or matched via StopNCII.org.
  • Terrorism and violent extremist content ("TVEC") — including, once AlemX GIFCT membership is active, hash matches via the GIFCT hash-sharing database.
  • Hate speech and discriminatory content.
  • Harassment and bullying.
  • Spam, scams, and inauthentic behavior.
  • Other policy violations.
• Detection source: user report, partner hash match, AlemX automated detection, AlemX human review, law-enforcement referral.

3.3 Account-level actions

• Account suspensions (temporary and permanent), with policy-category attribution.
• Account restorations following user appeal.
• Underage account removals (users determined to be below the minimum age, with handling per the AlemX child-safety policy).

3.4 User appeals

• Volume of moderation decisions appealed by users.
• Outcome of appeals: original decision upheld, original decision reversed, no decision within review window.
• Median time to appeal decision.

3.5 Privacy and data-subject requests

• Volume of data-access, data-correction, and data-deletion requests received from users.
• Disposition: honored, partially honored, declined (with reason categories).
• Median time to response.

3.6 Information about this report

• Methodology notes — how the figures in this report were compiled, including any caveats about category boundaries, data-collection limitations, or scope changes from prior reports.
• Year-over-year comparisons where prior periods are available.
• Material changes to AlemX policies during the reporting period that affected enforcement.

4. Publication Channel

• Primary location: alemx.com/legal/transparency
• Format: A long-form web page in English. PDF version generated from the same source and posted alongside the web page.
• Archival: Every prior report remains publicly available; AlemX does not retroactively edit or remove past reports. Corrections, when needed, are made by publishing a dated erratum in the current report.
• Notification: Publication of each report is announced via the AlemX blog, the AlemX social channels, and direct notification to civil-society and academic partners on AlemX's transparency-distribution list.

5. Methodology

Source of truth. Figures in each Transparency Report are compiled from AlemX's internal moderation tooling, the legal-request log maintained by the Compliance Coordinator, and AlemX's user-report intake system. AlemX commits to maintaining auditable records that support each reported figure.

Definitions. Each report will include a glossary defining every category reported. Where AlemX's category definitions differ materially from those used by peer platforms or by GIFCT, the report will say so explicitly and explain the difference.

Rounding and small-cell suppression. To protect against the re-identification of individuals from small aggregate counts, AlemX may suppress or band cells that fall below a small-number threshold. The threshold and the rule will be disclosed in the report's methodology section.

Independent review. AlemX will, beginning with the second full-period report, invite an external reviewer (academic or civil-society) to comment on the report's methodology and to identify gaps. Reviewer comments will be published as an appendix to the subsequent report.

6. Scope Limitations

The Transparency Report does not include:

• The substantive content of any user message, post, or account (the report deals only in aggregate counts and category-level information).
• Information protected by a statutory non-disclosure order accompanying a Government Request, for the duration of that order.
• Confidential terms of AlemX's vendor agreements, except where the vendor has authorized disclosure or where disclosure is required by law.

Where any limitation has materially reduced the figures that would otherwise have been reported, the report will say so in the methodology section, without breaching the underlying confidentiality obligation.

7. Governance

This Policy is owned by the Compliance Coordinator and reviewed at least annually. Material changes to the Policy require CEO approval and will be published as a new version of this document with a dated revision-history entry.

Inquiries about this Policy or about any published Transparency Report:

• Email: transparency@alemx.com
• Compliance Coordinator: Mehti Jalilzade — mehti@alemx.com

8. SOC 2 Mapping

9. Revision History