Digital Services Act (DSA)

Article 28 – Digital Services Act (DSA)
Online Protection of Minors

1. Platform Identification

Platform name: Unlockt.me
Operating entities:

• UNLOCKT.ME SAS (France)
• UNLOCKT.ME LLC (United States)

Nature of the service:
Digital content monetization platform operated in a strictly 18+ environment, with reinforced mechanisms to prevent access by minors.

Primary markets:
European Union, United Kingdom, United States

2. Scope of Article 28 of the DSA

Article 28 of the Digital Services Act applies to online platforms accessible to minors.

Unlockt.me is a platform that:

• is strictly restricted to users aged 18 and over,
• is not intended for minors,
• implements active measures to prevent minors from accessing its services.

Nevertheless, Unlockt.me voluntarily applies high standards of protection, safety, and prevention, in line with the principles and objectives of Article 28 of the DSA.

3. Measures Implemented by Unlockt.me

3.1 Prevention of Access by Minors

Unlockt.me implements the following measures:

• Explicit 18+ age restriction displayed upon access to the platform
• Mandatory age and identity verification (KYC) for creators and for access to monetization features, including:
  • verification of official identity documents,
  • verification of date of birth,
  • fraud and document tampering detection
• Immediate and permanent suspension of any account identified as belonging to a minor
• Zero-tolerance policy toward any attempt to circumvent age restrictions

These measures are designed to ensure that minors cannot access the services provided by Unlockt.me.

3.2 Privacy, Safety, and Security

Unlockt.me implements appropriate and proportionate measures to ensure:

• a high level of personal data protection (GDPR compliance),
• the security of users and transactions,
• the prevention and detection of illegal or harmful content, through:
  • automated moderation tools,
  • human review processes,
  • reporting and rapid takedown mechanisms,
  • cooperation with competent authorities where required.

3.3 Advertising and Profiling

Unlockt.me does not display advertising based on profiling, as defined in Article 4(4) of the GDPR.

In particular:

• no advertising is based on user behavior analysis,
• no personal data is used for targeted advertising purposes,
• consequently, no personal data of minors can be used for advertising purposes.

This approach complies with paragraph 2 of Article 28 of the DSA.

3.4 No Additional Personal Data Processing

In accordance with paragraph 3 of Article 28 of the DSA:

• Unlockt.me does not process additional personal data solely for the purpose of determining whether a user is a minor,
• compliance mechanisms rely exclusively on data that is strictly necessary for the provision of the service and compliance with legal obligations.

4. Governance and Continuous Improvement

Unlockt.me commits to:

• following any guidelines issued by the European Commission where applicable,
• maintaining a process of regular review of its compliance measures,
• adapting its processes in line with regulatory developments and identified risks.

5. Declaration

Based on the measures described above, Unlockt.me hereby certifies that it implements appropriate and proportionate measures in compliance with Article 28 of the Digital Services Act, both through the active prevention of access by minors and through a high level of privacy, safety, and security for its users.

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