Trust and safety policy

1.1 Purpose

This Policy sets out how Gathr detects, evaluates, and responds to harmful, fraudulent, or unlawful conduct on the platform, and how Users may report concerns and appeal enforcement decisions. It exists to protect Donors, Organisers, Beneficiaries, and the integrity of the platform itself, and to ensure Gathr's enforcement activity is lawful, proportionate, and consistent.

1.2 Governing Nigerian legal framework

This Policy is issued with reference to, and is intended to operate consistently with:

• The Cybercrimes (Prohibition, Prevention, etc.) Act, 2015, as amended by the Cybercrimes (Prohibition, Prevention, etc.) (Amendment) Act, 2024 (together, the "Cybercrimes Act"), including its provisions on child sexual abuse material, cyberstalking and online harassment, records retention, and mandatory incident reporting
• The Nigeria Data Protection Act, 2023 (NDPA) and the NDPC's General Application and Implementation Directive (GAID) 2025
• The Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA) and the Terrorism (Prevention and Prohibition) Act, 2022 (TPPA)
• The Federal Competition and Consumer Protection Act, 2018 (FCCPA)
• The Child Rights Act, 2003, and applicable State Child Rights Laws
• The Violence Against Persons (Prohibition) Act, 2015, to the extent it addresses technology-facilitated abuse
• The Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015 (TIPPEA), enforced by NAPTIP
• The Constitution of the Federal Republic of Nigeria, 1999 (as amended), in particular Section 39 (freedom of expression), which this Policy takes seriously in ensuring enforcement decisions are proportionate and not used to suppress legitimate campaign content, complaint, or criticism

1.3 Relationship to other policies

Where this Policy and Module 3 or Module 5 of the Terms of Service overlap on AML/CTF or prohibited-campaign matters, the more specific provisions of the Terms of Service control the underlying substantive prohibition, and this Policy governs the operational process by which that prohibition is detected, reviewed, and enforced.

2.1 Trust and Safety function

Gathr maintains a dedicated Trust and Safety function responsible for campaign screening, complaint handling, fraud investigation, and coordination with the Data Protection Officer described in the Privacy Policy and with law enforcement and regulatory bodies described in Module 8 below.

2.2 Three-tier review architecture

Consistent with industry patterns, Gathr operates enforcement through three tiers:

• Tier 1 - Automated pre-publication screening: Every campaign submission is screened by automated tools against the Prohibited Campaign categories in Module 5 of the Terms of Service, keyword and image-matching systems for known child sexual abuse material signatures, and sanctions-list screening under Module 1.3 of the Terms of Service, before the campaign is permitted to go live or, in higher-risk cases, while it is live and pending review.
• Tier 2 - Human review queue: Campaigns or reports flagged by Tier 1, or submitted through the reporting channel in Module 6 below, are escalated to a human reviewer within the Trust and Safety function. Gathr targets an initial human review determination within seventy-two (72) hours of a flag or report being received, save where the investigation requires additional evidence-gathering, legal advice, or coordination with a payment or verification partner.
• Tier 3 - Post-publication monitoring and audit: Live campaigns remain subject to ongoing automated monitoring for the suspicious activity indicators described in Module 3.3 of the Terms of Service, and to periodic manual audit sampling, so that a campaign which passed initial screening but later develops red flags (for example, a sudden mismatch between disclosed purpose and actual fund usage reported by Donors) can still be caught and escalated.

2.3 Escalation to senior review

Any enforcement decision resulting in permanent account termination, referral to a regulatory or law enforcement authority, or a fund freeze exceeding thirty (30) days must be reviewed and countersigned by a senior member of the Trust and Safety function or a designated compliance officer before being finalised, save where Module 3.4 of the Terms of Service requires immediate action to prevent ongoing harm.

3.1 Absolute prohibition

Consistent with the uniform industry practice, the following categories are treated as an absolute, non-negotiable zero-tolerance category, entirely outside the graduated enforcement system in Module 4 below. There is no warning, no grace period, and no contextual exception for these categories, irrespective of how a campaign or communication is framed:

• Any content depicting, describing, or facilitating access to child sexual abuse material, or grooming, in violation of the child pornography and related offences provisions of the Cybercrimes Act
• Any campaign or communication that facilitates trafficking in persons, in violation of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015
• Any campaign that finances or facilitates terrorism, in violation of the Terrorism (Prevention and Prohibition) Act, 2022, and the cyberterrorism provisions of the Cybercrimes Act
• Any content that constitutes non-consensual intimate imagery of any individual

3.2 Immediate and irreversible action

Upon detection or credible report of zero-tolerance content, Gathr will, without prior warning to the User:

• Immediately remove the content and suspend the associated account and any linked accounts
• Freeze all associated funds pending law enforcement direction
• Preserve all associated data, logs, and records pursuant to the records retention obligations described in Module 7 below
• Make a mandatory report to the Nigeria Police Force Cybercrime unit, the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) where trafficking is implicated, and, where the content involves a foreign national or foreign-hosted material, to the relevant international clearinghouse (such as the National Center for Missing & Exploited Children, where the platform's international donor base or hosting infrastructure brings that reporting channel into play)

3.3 No appeal for verified zero-tolerance violations

Consistent with industry-standard approach, an account terminated for a verified zero-tolerance violation under this Module has no right of appeal under Module 6 below. This exception exists because the category is, by design, defined narrowly enough that a false positive is both rare and independently reviewable by the senior escalation process in Clause 2.3, and because prompt, irreversible action is itself a legal and child-safety imperative.

4.1 Proportionality and free expression safeguard

In determining enforcement action for content-based violations (as distinct from financial-crime or fraud violations), Gathr's Trust and Safety function will have regard to the constitutional protection of free expression under Section 39 of the Constitution, and will avoid using this Policy to suppress legitimate fundraising narratives, criticism of public institutions, or advocacy content, mindful of documented concerns, including from Nigeria's National Human Rights Commission, regarding the misuse of cyberstalking-type provisions to stifle lawful expression. Enforcement under this Policy is directed at conduct that is fraudulent, harmful, or unlawful, not at the viewpoint expressed within a lawful campaign.

5.1 Children and minor beneficiaries

Where a campaign names a minor as a Beneficiary, the adult Organiser bears sole responsibility for ensuring any personal or medical information about the minor is disclosed appropriately and with lawful consent, as set out in Section 8 of the Privacy Policy. Gathr's Trust and Safety function will additionally screen such campaigns for signs of exploitation, and will escalate any suspected case of child exploitation to the zero-tolerance process in Module 3 above.

5.2 Technology-facilitated gender-based violence

Gathr treats harassment, doxxing, non-consensual disclosure of private information, and cyberstalking conducted through campaign updates, comments, or direct messaging on the platform as serious violations under Module 4 above, having regard to the cyberstalking provisions of the Cybercrimes Act and the protections available under the Violence Against Persons (Prohibition) Act, 2015. Reports of this nature are prioritised for expedited Tier 2 human review.

5.3 Politically exposed persons and financial vulnerability

Where Enhanced Due Diligence flags a campaign under Module 3.2 of the Terms of Service, Trust and Safety review of that campaign's content is conducted jointly with the AML/CTF compliance function to avoid duplicated or inconsistent findings.

6.1 How to report a concern

Any User, or member of the public, may report a campaign, User, or piece of content through the in-platform reporting tool or by email to the Trust and Safety contact address published on the platform. Reports should include the campaign or account identifier, a description of the concern, and any supporting evidence.

6.2 Acknowledgement and investigation timeline

Gathr will acknowledge receipt of a report within forty-eight (48) hours. Non-urgent reports are resolved within the Tier 2 review window described in Clause 2.2. Reports alleging zero-tolerance conduct under Module 3 are prioritised immediately ahead of all other queued matters.

6.3 Notice of enforcement action

Save where notice would be unlawful (for example, where notice would breach the anti-tipping-off provisions of Module 3.4 of the Terms of Service in an active financial-crime investigation, or where notice would compromise a zero-tolerance investigation under Module 3 above), Gathr will notify a User of an enforcement action taken against their account or campaign, the specific provision found to have been breached, and the available remedy.

6.4 Right of appeal

A User subject to enforcement action under Module 4 (the graduated system) may submit a written appeal within fourteen (14) days of notice, setting out the grounds on which they believe the decision was made in error. Appeals are reviewed by a member of the Trust and Safety function who was not involved in the original decision. Gathr aims to determine appeals within fourteen (14) business days of receipt. If an appeal is successful, the enforcement action is reversed and, where applicable, any wrongly withheld funds are released.

6.5 Abuse of the reporting and appeals process

Submitting manifestly unfounded, repeated, or bad-faith reports or appeals with intent to harass another User or disrupt a legitimate campaign is itself a violation of this Policy and may result in enforcement action against the person submitting the report.

7.1 Retention obligation

In accordance with the records retention obligations under the Cybercrimes Act and the AML/CTF record-keeping requirements referenced in the Privacy Policy, Gathr retains logs, communications, campaign content (including removed content), and transaction records relevant to a Trust and Safety investigation for a minimum of the periods specified in Section 12 of the Privacy Policy, and, where a matter is subject to an active investigation, law enforcement request, or legal proceeding, for so long as necessary to support that process.

7.2 Preservation requests

Gathr will preserve relevant data upon a valid preservation request from a Nigerian law enforcement agency or a foreign agency acting through a recognised mutual legal assistance or international cooperation channel, pending formal legal process for disclosure.

8.1 Evaluation of requests

Gathr carefully evaluates every government or law enforcement request for User data to ensure it is legally valid, proportionate, and issued by a competent authority, before disclosing any data, save in the circumstances described in Clause 8.3.

8.2 Standard process

Save for urgent cases described below, Gathr requires a valid court order, warrant, or other legally binding instrument issued by a Nigerian court or a competent authority acting under Nigerian law (or a recognised foreign equivalent transmitted through an appropriate international cooperation mechanism) before disclosing User data to a law enforcement or government body.

8.3 Urgent and emergency disclosure

Where the Cybercrimes Act (as amended in 2024) permits interception or disclosure without a prior court order in genuinely urgent circumstances, or where Gathr reasonably believes disclosure is necessary to prevent imminent death or serious bodily harm to any individual, Gathr may disclose the minimum data necessary without awaiting formal legal process, and will document the basis for that determination.

8.4 Mandatory regulatory reporting

Nothing in this Module limits or delays Gathr's mandatory reporting obligations to the Nigerian Financial Intelligence Unit (NFIU), SCUML, EFCC, or NAPTIP described in Module 3.4 of the Terms of Service and Module 3.2 above, which operate independently of, and are not conditioned upon, a prior request from those bodies.

9.1 Good faith decision-making

Consistent with the protection extended to Gathr's officers under the Refund Policy, no director, officer, employee, contractor, or agent of Gathr involved in a Trust and Safety determination made in good faith and in accordance with this Policy shall bear personal liability for that determination. Any claim arising from an enforcement decision must be brought against Gathr Technology Limited and not against the individual reviewer.

9.2 Whistleblower and internal reporting protection

An employee, contractor, or agent of Gathr who in good faith reports a suspected violation of this Policy, the Terms of Service, or applicable Nigerian law, whether committed by a User or by another member of Gathr's personnel, shall not be subject to retaliation, demotion, or termination for having made that report, save where the report is knowingly false or made in bad faith.

9.3 Duty of care and reasonable resourcing

Gathr commits to providing its Trust and Safety personnel with reasonable training, escalation support, and access to legal guidance necessary to make sound determinations under this Policy, recognising the psychological demands of reviewing harmful content, particularly within the zero-tolerance category.

10.1 Policy review

This Policy is reviewed periodically to reflect changes in Nigerian law, evolving fraud and abuse patterns, and developments in industry best practice.

10.2 Amendments

Amendments to this Policy are made in accordance with the unilateral amendment provisions set out in Module 1.4 of the Terms of Service.

Nothing in this Policy expands Gathr's liability beyond the limitation of liability provisions set out in Module 6.3 of the Terms of Service, and nothing in this Policy shall be construed as a warranty or guarantee that Gathr's detection systems will identify every instance of harmful or unlawful content, given the acknowledged limitations of automated moderation technology.