Customer Terms and Conditions (18+)
Dated August 27, 2025
These Customer Terms and Conditions (18+) are entered into between you ("You" or "User") and Pochemu LTD, a company incorporated under the laws of the Republic of Cyprus, with its registered office at Agias Zonis & Thessalonikis, 3026, Limassol, Cyprus ("We", "Pochemu", or the "Company").
By accessing, viewing, or using the Website, the Game, or any Services provided by Pochemu, You expressly acknowledge and agree to be legally bound by the terms, conditions, and provisions set forth in this Agreement. It is essential that You read this Agreement carefully before using any part of the Services.
IF YOU DO NOT AGREE TO ANY UPDATED TERMS, OR IF YOU DO NOT MEET THE AGE REQUIREMENTS SPECIFIED HEREIN, OR IF YOUR ACCESS OR USE OF THE SERVICES IS PROHIBITED UNDER THE LAWS OF YOUR JURISDICTION, YOU MUST IMMEDIATELY DISCONTINUE YOUR USE OF THE SERVICES.
1. Definitions
2. Age-Restricted Materials and Age Restricted Access
3. Prohibited Use
4. Account and Password
5. Use of Services and Credits
6. Payment
7. Refund Policy
8. User Conduct
9. Moderation and Enforcement
10. Cancellation or suspension
11. Term and Termination
12. Warranties and disclaimers
13. Third-Party Services
14. Intellectual Property
15. Miscellaneous
SCHEDULE X – UK AGE ASSURANCE ADDENDUM
(Online Safety Act 2023, Part 5 – Pornographic Content)
Effective Date: 1 July 2025
Document Status: This Schedule forms part of, and must be read together with, the Customer Terms and Conditions (18+) and the End‑User Licence Agreement (collectively, the “User Agreement”). Where there is any conflict, this Schedule prevails in respect of Users in the United Kingdom or Users accessing the Services from the United Kingdom.
1. Definitions
“OSA 2023” means the Online Safety Act 2023 of the United Kingdom.
“Ofcom” means the Office of Communications, the statutory regulator under the OSA 2023.
“UK User” means any natural person who (i) is physically present in the United Kingdom or (ii) accesses the Services using a UK‑registered payment method, telephone number, or Internet Protocol (IP) address reasonably associated with the United Kingdom.
Other capitalised terms have the meaning given to them in the User Agreement.
2. Applicability and Precedence
2.1 This Schedule applies to all UK Users and governs the publication or display of pornographic content within the meaning of Part 5 OSA 2023.
2.2 If a provision of this Schedule conflicts with any other part of the User Agreement, the provision in this Schedule controls solely for UK Users.
3. Age‑Assurance Duty
3.1 Legal Obligation. In accordance with sections 72–77 OSA 2023, we must ensure that children (persons under 18 years) are not normally able to encounter pornographic content on the Services.
3.2 Highly Effective Age Assurance. Prior to granting a UK User access to any pornographic content, we will apply a “highly effective” age‑assurance measure, as that term is defined in Ofcom’s Guidance on Highly Effective Age Assurance and other Part 5 Duties (the “Ofcom Guidance”).
3.3 Acceptable Methods. The following age‑verification or age‑estimation solutions (individually or in combination) are recognised by Ofcom as capable of meeting the “highly effective” standard and may be deployed by the Company:
● Digital photo‑ID matching against a government‑issued document (passport, driving licence, CitizenCard, etc.), verified by a certified identity‑service provider;
● Facial age‑estimation technology meeting ISO/IEC 24027 or equivalent accuracy benchmarks;
● Mobile Network Operator (MNO) age‑check utilising the UK Age Verification Association (AVA) standard;
● Open‑Banking (Account Information Service) verification confirming that the account holder is 18 +; and
● Credit or debit card verification combinedwith 3‑D Secure authentication and date‑of‑birth matching held by the card issuer.
3.4 Prohibited Methods. Self‑certification tick‑boxes, non‑verified payment details, or relying solely on the user’s declaration do not satisfy the “highly effective” threshold and are not used for UK Users.
3.5 No Preview. No still image, clip, or textual description capable of causing a sexual response will be displayed until the age‑assurance process has been successfully completed.
3.6 Anti‑Circumvention Controls. Technical and organisational measures— including rate‑limiting, session binding, automated detection of anonymisation tools (e.g. VPNs), and regular integrity checks—are maintained to prevent circumvention.
4. Implementation Framework
4.1 Third‑Party Providers. We engage only providers that: (a) are certified under the Age Check Certification Scheme (“ACCS”) or an equivalent, (b) operate under UK GDPR / DPA 2018, and (c) provide independent conformity‑assessment reports on accuracy and bias.
4.2 User Flow.
Step 1: User is informed that age verification is mandatory to continue;
Step 2: User selects one of the approved verification methods;
Step 3: The provider performs verification and returns a yes/no token—no date of birth or document image is retained by the Company;
Step 4: A non‑transferable age‑verified session credential is stored (max 30 days) to minimise repeated checks.
4.3 Accessibility & Fairness. At least one non‑biometric verification route is offered at no monetary cost to the user. Reasonable adjustments are available for disabled users in line with the Equality Act 2010.
4.4 Review Cycle. Effectiveness metrics (false‑negative and false‑positive rates, attempted circumventions) are reviewed quarterly and after any material platform change.
5. Data Protection & Privacy
5.1 Lawful Basis. Processing is necessary for compliance with a legal obligation (Article 6(1)(c) UK GDPR).
5.2 Data Minimisation. We receive only the minimum data needed—typically a binary confirmation of “18 or over.” ID images or biometric templates are processed exclusively by the third‑party provider and are not stored by the Company.
5.3 Retention.Age‑verified tokens are retained for a maximum of 30 days or until the user deletes their account, whichever is sooner. Backend logs required for security and audit are retained for up to 12 months.
5.4 Security Measures. All data in transit is protected with TLS 1.3 or higher; all data at rest is encrypted with AES‑256 or better.
5.5 User Rights. UK Users may exercise their rights of access, deletion, or restriction by contacting the Compliance Manager (see section 7).
6. Record‑Keeping & Transparency
6.1 Internal Records. The Company maintains contemporaneous records of (a) the chosen age‑assurance methods, (b) the decision‑making process, (c) accuracy tests, (d) vendor due‑diligence, and (e) quarterly effectiveness reviews.
6.2 Public Statement. A concise, plain‑language Age Assurance Summary is published on the Website, describing (i) why age assurance is required, (ii) which methods are used, and (iii) how user privacy is protected.
6.3 Audit Trail. Upon lawful request from Ofcom, we will provide relevant documents within 10 UK business days.
7. Ofcom Engagement & Contact
7.1 E-mail: support@pochemultd.com
7.2 Cooperation. The Company will:
● cooperate with Ofcom investigations under sections 100–106 OSA 2023;
● report any material security incident affecting age‑assurance data within 72 hours; and
● implement remediation actions mandated by Ofcom within the specified deadlines.
8. Enforcement Within the Services
8.1 A User who attempts to bypass or otherwise undermines the age‑assurance system is in material breach of the User Agreement and may have their Account suspended or terminated without refund.
8.2 Where the Company reasonably believes that a User is a child, access to pornographic content will be blocked pending successful verification.
9. General Provisions
9.1 Severability.Should any clause in this Schedule be held invalid, the remaining clauses remain in full force and effect.
9.2 Amendments.We may amend this Schedule to reflect changes in law or Ofcom Guidance. Material changes will be notified to UK Users at least 14 days in advance.
9.3 Governing Law. This Schedule is governed by the laws of England and Wales and subject to the exclusive jurisdiction of the courts of England and Wales.
End of Schedule X – UK Age Assurance Addendum
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