SWIPEY VERIFIED MODEL ONBOARDING POLICY

Page: Swipey.ai

Effective Date: 01st day of January 2026

Version: 1.0 (Platform & AI Twin Specific)

Welcome to Swipey AI

1. Purpose:

This Creator Onboarding Policy (the "Policy") establishes the legal, operational, and compliance framework for identifying, verifying, and onboarding individuals whose likeness may be used to create AI-generated avatars ("AI Twins") on the Swipey.ai platform.

Swipey.ai operates exclusively as an AI-generated content platform. All user interactions occur with artificial intelligence systems.

This Policy ensures that Creator participation is lawful, voluntary, transparent, and free from exploitation or coercion.

2. Scope:

This Policy applies globally to:

• Individuals applying to become Verified Models ("Creators")
• Internal onboarding, compliance, and moderation teams
• Third-party KYC / identity verification providers
• Vendors involved in AI training, data processing, or infrastructure

For the avoidance of doubt: Swipey.ai does not onboard Creators as performers, entertainers, live content providers, or user-facing content producers. Creators license certain likeness and personality attributes solely for the creation and operation of AI Twins in accordance with the AI Twin Likeness & Content Agreement.

3. Definition of Creator:

A "Creator" (or "Verified Model") is a verified adult individual who has provided explicit legal consent for their likeness (including but not limited to image, voice, and personality attributes) to be used as a reference dataset for the creation and operation of an AI-generated avatar ("AI Twin").

A Creator shall not be considered:

• an employee or agent of the platform
• a participant in real-time interactions with users
• a party entitled to control individual AI-generated outputs

4. Relationship to Other Agreements:

In the event of any conflict between this Policy and any other agreement, the following order of precedence applies:

• AI Twin Likeness & Content Agreement (primary contractual terms)
• This Onboarding Policy (operational and compliance rules)
• Model Release (the standalone Model Release shall not apply to the Creator onboarding process unless expressly incorporated as an exhibit or short-form age, identity and consent attestation).

5. Core Onboarding Principles:

Swipey.ai onboarding is governed by the following principles:

• Voluntary Participation - Free from coercion or third-party control.
• Verified Identity & Age - 18+ with valid government ID and liveness check.
• Informed Consent - Creator understands: AI Twin, no human-to-human interaction, no real-time control.
• AI-Only Platform Integrity – Strict separation between human Creator and AI Twin.

6. Creator Onboarding Process:

• Application & Screening – Submission of personal details and consent to verification. Swipey.ai reserves the right to reject any application.
• Identity Verification (KYC) – Government ID, biometric/photo verification, liveness checks via third-party provider (e.g., ONDATO).
• Execution of Legal Agreements – Creator must execute the AI Twin Likeness & Content Agreement (not the standalone Model Release). The Model Release, if used at all, must be a short-form attestation of age and identity only, attached as an exhibit to the AI Twin Agreement.
• Submission of Materials – Photos, videos, voice samples, personality descriptors. Used exclusively for AI training and avatar generation. Raw materials are not made publicly available.
• AI Twin Creation & Deployment – AI Twin operates autonomously. Creator does not control real-time outputs and is not required to be active online.

7. Prohibited Onboarding Categories:

Swipey.ai strictly prohibits onboarding of:

• Individuals under 18 or age-ambiguous
• Individuals acting under coercion or third-party control
• Impersonators or individuals misrepresenting identity
• Individuals unable to provide valid identification
• Individuals attempting to onboard using third-party likeness

8. Consent, Revocation & Lifecycle:

8.1 Consent – Must be explicit, documented, legally valid, and separately confirmed for AI training and public deployment.

8.2 Revocation & Deletion – Creator may request termination of future use of their likeness and permanent deletion of their AI Twin. Swipey.ai shall complete deletion within 14 calendar days from verified request. After deletion, the AI Twin will not generate new content.

8.3 Post-Termination – Existing Content – If Creator revokes consent:

• Previously generated content may remain on the platform (as licensed use under the AI Twin Agreement)
• Creator's likeness will not be used for new generation
• Creator may request deletion of all existing AI-generated content (right to be forgotten under GDPR Art.17). Swipey.ai will assess and process such request in accordance with GDPR Article 17 and applicable legal exceptions, normally within 30 days.

8.4 AI Disclosure Obligation – All AI Twins will clearly identify themselves as AI during first interaction (e.g., "I am an AI-generated character based on licensed likeness materials and not the real person").

9. Compensation Framework (Referral-Based Revenue Share):

9.1 Overview:

Creators are compensated exclusively through a referral-based revenue share model. Compensation is not based on AI Twin interactions, token spend allocation, or any activity of the Creator's own AI Twin. Instead, Creators earn by referring new paying users to the Swipey.ai platform.

9.2 How It Works:

9.3 Attribution Model – Last Paid Click:

Swipey.ai uses a Last Paid Click attribution model: "Last Paid Click" means that the last click on a Creator's referral link before a user makes a monetary transaction determines which Creator receives credit for that transaction, regardless of how the user previously arrived at the platform.

Important rules:

• If a user clicks multiple referral links, the last click before payment wins
• The user does not need to interact with the Creator's AI Twin
• The user does not need to pay the Creator directly
• The Creator receives credit even if the user spends tokens or subscribes to another Creator's AI Twin

9.4 Revenue Share Percentage:

For Individual Creators (no studio/agency): 70% of Net Revenue from each qualifying user transaction attributed to the Creator's referral link.

For Creators registered under a Studio (Agency):

Clarification: The exact split shall be specified in Exhibit A of the AI Twin Agreement. The example above is illustrative.

9.5 Definition of "Net Revenue":

Net Revenue means the monetary amount actually received by Swipey.ai from a user's transaction, after deducting:

• Value Added Tax (VAT) for European Union customers
• Chargebacks
• Refunds
• Any other taxes, payment processing fees, fraud-related reversals, or deductions required by law or payment processors.

Any other taxes, fees, or reversals required by law or payment processors.

Net Revenue is calculated per transaction, not per token or per interaction.

Important: Creators do not earn from:

• Token spend allocation (regardless of how many tokens the user spends or on whom)
• Organic traffic (users who arrive without clicking a referral link)
• Non-monetary activity (free accounts, trials, etc.)

9.6 Attribution Period:

Once a user is attributed to a Creator under the Last Paid Click model, that attribution remains valid for one (1) year from the date of the user's registration.

During this 1-year period the Creator earns 70% of Net Revenue from all monetary transactions made by that user. This applies regardless of where the user spends tokens or which AI Twins the user interacts with.

After 1 year:

• Attribution expires
• Further transactions from that user do not generate revenue for the Creator

9.7 Payment Terms:

9.7.1 Holding Period - all transactions are subject to a 14-day holding period from the transaction date. During this period, funds are not available for withdrawal. The holding period allows Swipey.ai to process chargebacks, refunds, and fraud checks.

9.7.2 Withdrawal - after the 14-day holding period expires, funds become available for withdrawal. Available withdrawal methods (specified in Exhibit A of the AI Twin Agreement):

• Bank transfer
• PayPal
• Tipalti (or equivalent payout processor)

9.7.3 Minimum Payout Threshold - Swipey.ai may set a minimum payout threshold (e.g., $50 / €50). Any amount below the threshold will roll over to the next payout period.

9.7.4 Payment Schedule - Payments are processed monthly (unless otherwise specified in Exhibit A).

9.8 No Earnings from Organic Traffic:

Creators do not receive any compensation from users who arrive at Swipey.ai through organic traffic (direct traffic, search engines, social media without a referral link, or any other source not attributable to the Creator's unique referral link).

9.9 No Earnings from AI Twin Activity:

Creators are not compensated for:

• Interactions with their own AI Twin
• Time spent by users on their AI Twin
• Token spend allocated to their AI Twin (unless the user was originally referred by that Creator – see Section 9.6). Compensation is purely referral-based.

9.10 No Guaranteed Earnings:

Swipey.ai does not guarantee any minimum earnings. Creators earn only when they successfully refer paying users.

10. Content Safety & Platform Controls:

All AI Twins are subject to automated moderation, prompt filtering, and safety alignment controls.

Swipey.ai strictly prohibits:

• Generation of minors or age-ambiguous characters
• Non-consensual or exploitative scenarios
• Impersonation of real individuals
• Any content that may violate applicable laws

11. Data Protection & Security:

Creator data is processed in accordance with:

• GDPR (EU) 2016/679
• Applicable Cyprus data protection laws

Swipey.ai implements access control restrictions, encryption, secure storage, and data minimisation principles.

12. Third-Party Compliance:

All third-party providers involved in identity verification, data processing, or AI training must comply with applicable legal standards, anti-slavery obligations, and operate under contractual safeguards.

13. Breach & Enforcement:

Violation of this Policy may result in:

• rejection of onboarding
• suspension or termination of agreements
• removal of AI Twin
• legal action where applicable

14. Governing Law & Disputes:

This Policy and all related agreements shall be governed by the laws of Cyprus. Any disputes shall be resolved exclusively by the courts of Cyprus.

15. Governance & Review:

Responsible roles: Compliance Officer, Legal Department, Trust & Safety. This Policy shall be reviewed annually or upon material changes to the platform.

16. Contact:

For onboarding, legal, or compliance inquiries: Email: compliance@swipey.ai