- Terms of Services
- Terms of Use for Creators (Appendix 1)
- Terms of Use for Fans (Appendix 2)
- Referral Program Terms (Appendix 3)
- Acceptable Use Policy (Appendix 4)
- Community Guidelines (Appendix 5)
- Report and Complaint Policy (Appendix 6)
- KYC Procedures and Requirements (Appendix 7)
- Relevant Legislations (Appendix 8)
- Anti Human Trafficking Statement (Appendix 9)
Wink combats and has zero tolerance for modern slavery. We are committed to building the safest digital media platform (the “Platform”) for interactions between Creators and Fans and we do not tolerate any form of modern slavery or human trafficking on our Platform. Unless otherwise defined, capitalised terms used herein has the same meaning as those defined in Terms of Use for All Users (the “Terms”).
This statement is made pursuant to the Company’s values and goals, and in line with applicable legislations for our Platform such as the Modern Slavery Act 2015 of the United Kingdom, Modern Slavery Act 2018 of Australia, and the California Transparency in Supply Chains Act. It sets out the steps taken by Wink to ensure that modern slavery and human trafficking is not taking place in our platform.
Our Commitment
Wink stands against all forms of modern slavery and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We are committed to combat modern slavery and human trafficking in our business dealings and relationships with our Creators and Fans. We are also committed to promulgate fair treatment for all our employees, consultants, contractors, partners and vendors with respect and dignity, ensuring safe and harmonious conditions in the course of our business dealings.
Our Policies
Wink is committed to taking all reasonable and appropriate steps to ensure that there are no modern slavery or human trafficking activities taking place on our Platform, some of the examples include:-
- We have a Code of Conduct (the “Code”) in place which sets out our expectation that all our employees act with integrity and to exercise good and independent judgment in their efforts to comply with all Applicable Laws, rules, and regulations, including in relation to modern slavery and human trafficking. This Code is also shared with key collaboration partners and vendors.
- Our Terms specifically prohibits the uploading, posting, displaying, or publishing of Contents on Wink that (i) shows, includes or refers to any other individual unless written consent is obtained from each individual to use their name or images (or both) in the Content; or (ii) shows, promotes, advertises or refers to escort services, sex trafficking, or prostitution.
Our Risk Assessment
We continually assess modern slavery and human trafficking risks in our business environment through identifying and analysing higher-risk areas of our business. Our assessment is based on external reports and standards, with reference to the jurisdictions where we operate, and we adjust our processes and controls, as appropriate, based on evolving risks for the use of the Services of our Platform.
Our Business Operations
We consider the risks of modern slavery and human trafficking to be relatively low in our direct business operations as our workforce is comprised of professionally qualified or skilled personnel. We recognise that there might be risks of modern slavery and human trafficking as we employ contractors from time to time in different jurisdictions for our operation of business. In order to mitigate this, we ensure that our workforce would be abreast of the latest development of modern slavery and human trafficking, and that they can report any instances of suspected modern slavery or human trafficking through our Communication Portal or Report and Complaint Policy.
Creator Verification
We and our Third Party Service Providers carefully conduct KYC and check the identity for each Creator, in which all of them should attain the Age of Majority in the jurisdictions they reside in. We specifically check for any discrepancies between identity documents and the legal name provided on payment methods, and employ technological safeguards to prevent Creator’s payment details from being changed by any malicious hackers. We also update our KYC Procedures and Guidelines from time to time to ensure compliance with all the Applicable Laws.
Content Moderation
In order to prevent and detect Contents that violate our Community Guidelines and Acceptable User Policy, we monitor all the Contents uploaded to the Platform and remove, and report where necessary, any content that facilitates or coordinates the exploitation of people, including modern slavery and human trafficking. We have continued to enhance the depth and sophistication of our content moderation to ensure compliance with our Terms. All our content moderators are trained to identify and swiftly report any suspected modern slavery including trafficking. Our trained moderators identify, and immediately report any content which they suspect may be an indicator of modern slavery or human trafficking. We can review and remove any Contents shared on our Platform at any time. Our technical team will also publish reports that include the content moderation, including information relating to illegal content, use of automated tools, training measures, and complaints received under our Communication Portal and Report and Complaint Policy.
Commercial Relationship
When we enter into commercial agreements with potential vendors, we consider the relevant provisions of our Code, the Terms, the Acceptable Use Policy and this Anti Human Trafficking Statement to ensure these agreements align with our policies against modern slavery and human trafficking.
Our Reporting Mechanisms
We foster a culture of transparency, honesty and accountability, which encourages our Users to report any concerns or wrongdoings, including human rights violations, modern slavery and human trafficking. If you have any concerns or suspect any Contents posted by any Users are in contravention of any of our policies in the Platform, please report it through our Report and Complaint Policy or Communication Portal.