Transparency and Governance Policy

This Transparency and Governance Policy ("Policy") establishes the principles, guidelines, and commitments adopted by Myclose.fan ("Platform"), to ensure:

• integrity;
• predictability;
• accountability;
• legal certainty;
• trust in the ecosystem.

The Platform seeks to balance creative freedom, user protection, legal compliance, and business sustainability.

The Platform's governance is guided by the following principles:

• Legality: acting in accordance with applicable legislation;
• Accountability: each agent is responsible for their actions;
• Proportionality: measures compatible with the identified risk;
• Good faith: ethical and transparent conduct;
• Security: protection against fraud, abuse, and unlawful acts;
• Prevention: proactive action to mitigate risks;
• Responsible transparency: clear communication without exposing sensitive information.

3.1. Platform

The Platform:

• provides technological infrastructure;
• establishes rules and policies;
• acts in risk prevention;
• intermediates payments;
• applies governance measures.

3.2. Creators, sellers, and organizers

They are responsible for:

• content, products, events, and offers;
• compliance with policies;
• proper data handling;
• user support.

3.3. Users

They are responsible for lawful use of the Platform and for respecting the rules and the community.

The Platform makes its main institutional documents accessible, including:

• Terms of Use;
• Creator Terms;
• Privacy Policy;
• Cookies and Technologies Policy;
• Payments, Refunds, and Chargebacks Policy;
• +18 Content and Moderation Policy;
• Transparency and Governance Policy;
• DPA -- Data Protection Addendum for Creators.

These documents form an integrated governance framework.

5.1. Monitoring and prevention

The Platform may adopt measures including:

• technical monitoring;
• automated and manual analysis;
• investigation of reports;
• compliance verification.

These measures aim to:

• prevent minors' access;
• prevent fraud;
• curb abuse;
• comply with legal obligations.

5.2. General decision criteria

Decisions may consider, among other factors:

• severity of conduct;
• recurrence;
• legal, financial, or reputational risk;
• impact on users and third parties;
• available technical evidence.

The Platform does not disclose details of algorithms, thresholds, or internal systems, for security reasons.

5.3. Applicable measures

Depending on the case, the following may be applied:

• warnings;
• content removal;
• feature limitations;
• value retention;
• temporary suspension;
• permanent account termination;
• notification to competent authorities.

Measures may be preventive, including before the conclusion of investigations.

The Platform adopts a zero-tolerance policy for fraudulent practices, including:

• self-fraud;
• metric manipulation;
• misuse of payment methods;
• exploitation of system flaws;
• creation of fake or multiple accounts.

Identified cases may result in severe sanctions, including value retention and banning.

The Platform:

• processes personal data in accordance with legislation;
• discloses legal bases and purposes;
• adopts security measures;
• respects data subjects' rights.

Details are described in the Privacy Policy and the DPA, when applicable.

The Platform maintains internal processes for:

• dispute analysis;
• chargeback response;
• cooperation with financial institutions;
• use of technical evidence.

Decisions follow governance, security, and compliance criteria.

The Platform may communicate through:

• email;
• internal notifications;
• logged-in areas;
• official support channels.

Not all decisions allow for individualized detail, especially when there is:

• security risk;
• legal confidentiality;
• ongoing investigation.

The Platform cooperates with competent authorities whenever there is a legal obligation, court order, or need to prevent unlawful acts, respecting legislation and fundamental rights.

Whenever appropriate, the Platform may:

• review policies;
• improve governance mechanisms;
• communicate relevant changes.

Governance is dynamic and evolves according to risks, technology, and legislation.

For reasons of security, system integrity, and trade secrets, the Platform is not required to disclose:

• algorithms;
• anti-fraud methods;
• specific technical criteria;
• internal strategic information;
• third-party data protected by confidentiality.

This Policy may be updated at any time. The current version will always be the one published on the Platform.

Continued use implies acceptance.

For questions related to this Policy:

Email: atendimento@myclose.fan