Customer Terms and Conditions (18+)
Effective Date: December 18, 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. Anti-Trafficking, Sex Trafficking and Abuse policy
10. Moderation and Enforcement
11. Cancellation or suspension
12. Term and Termination
13. Warranties and disclaimers
14. Third-Party Services
15. Intellectual Property
16. Miscellaneous
SCHEDULE 1 - UK AGE ASSURANCE ADDENDUM
(Online Safety Act 2023, Part 5 – Pornographic Content)
Effective Date: 18 December 2025
Document Status: This Schedule forms part of, and must be read together with, the Customer Terms and Conditions (18+) (the “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
Other capitalised terms have the meaning given to them in the 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 of the Online Safety Act 2023 (as amended).
2.2 If a provision of this Schedule conflicts with any other part of the Agreement, the provision in this Schedule controls solely for UK Users.
3. Age-Assurance Duty
3.1 Legal Obligation. In accordance with Part 5 of the Online Safety Act 2023 (as amended), 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 Guidance as capable of meeting the “highly effective” standard and may be deployed by the Company:
3.4 Prohibited Methods. Self-certification tick-boxes, non-verified payment details, or relying solely on the user’s declaration do not satisfy the industry standard 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 industry-standard encryption (for example 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:
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 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 1 - UK Age Assurance Addendum
SCHEDULE 2 - Anti-Trafficking, Sex Trafficking and Abuse Policy
Effective Date: 18 December, 2025
1. Purpose and scope: This Policy sets out the Company’s zero-tolerance approach to human trafficking, sex trafficking, sexual exploitation, forced labor, and abuse (together, Trafficking-Related Activity). This Policy applies to all Users, all use of the Website, the Game, and the Services, and any communications, interactions, or user-generated functionality made available within the Services.
2. Zero tolerance and explicit prohibition: The Company strictly prohibits any use of the Website, platform, or Services that promotes, facilitates, enables, advertises, solicits, or attempts to arrange human trafficking, sex trafficking, or any form of abuse or exploitation of any person. This prohibition applies to all features, including any user communications, user-generated functionality, profiles, links, or redirection mechanisms.
3.Enforcement mechanisms and internal controls. The Company maintains internal controls designed to prevent and address Trafficking-Related Activity, which may include:
a. moderation and enforcement actions, including Content removal, access restriction, account suspension or termination, and payment access restriction;
b. risk-based monitoring of user activity signals and user-generated functionality where available;
c. detection and disruption of attempts to circumvent safety measures, including repeated policy violations, evasion patterns, or abusive account behavior; and
d. record-keeping of relevant enforcement actions and security logs for audit, legal, and safety purposes, subject to applicable data protection law.
e. automated and human review workflows for high-risk signals (including repeated reports, solicitation patterns, suspicious links or contact-sharing attempts);
f. preservation of relevant logs and evidence;
g. restriction of payment access and coordination with payment partners where appropriate.
4. Reporting and escalation
4.1 How to report. Users and third parties may report suspected Trafficking-Related Activity using the channels set out in the Complaints and Takedown Policy.
4.2 Escalation. Credible Reports are escalated to the Company’s designated compliance function for assessment and decision-making. Where appropriate or required, the Company may escalate matters to law enforcement, regulators, and relevant third parties (including payment and platform partners) and preserve relevant logs and evidence to support investigations.
4.3 Cooperation. Where appropriate or required, the Company may cooperate with competent authorities, regulators, and relevant third parties (including payment and platform partners). The Company may preserve relevant logs and evidence to support investigations, consistent with applicable law.
5. Active efforts to prevent trafficking-related activity. The Company takes active steps to reduce trafficking-related risk, which may include:
a. maintaining clear user rules and enforcing them consistently;
b. restricting features that are commonly abused for exploitation or solicitation;
c. performing risk-based reviews of user behavior patterns and repeated violations;
d. maintaining internal guidance for staff involved in moderation and escalation; and
e. reviewing effectiveness of controls periodically and improving controls in response to emerging risks.
6. Non-retaliation and good faith reporting: The Company does not tolerate retaliation against any person who makes a good-faith Report. Abusive or bad-faith reporting may itself result in enforcement action.
7. Contact. General support and reporting contact: support@pochemultd.com
SCHEDULE 3 - Complaints and Takedown Policy
Effective Date: 18 December, 2025
1. Purpose: This Policy explains how to submit complaints and Reports regarding unlawful content, policy violations, exploitation, abuse, or Trafficking-Related Activity, and how the Company reviews and responds.
2. Reporting channels. Reports may be submitted via:
a. Web form: /complaints-and-takedown (or another reporting form made available on the Website)
b. Email: support@pochemultd.com
3. What to include in a Report. To help us investigate efficiently, please provide:
a. your name and contact email (unless prohibited by law or safety concerns);
b. the username/account identifier involved (if known);
c. a clear description of the concern;
d. direct URLs, screenshots, timestamps, message IDs, or other identifiers relevant to the content or conduct; and
e. any context showing why you believe the activity is unlawful or involves exploitation, abuse, or Trafficking-Related Activity.
4. Our process and timeframes:
4.1 Acknowledgement. We will confirm receipt of your Report within 2 Business Days.
4.2 Triage. We prioritize Reports involving suspected Trafficking-Related Activity, exploitation, or imminent harm.
4.3 Urgent action. Where we reasonably believe Content or conduct involves Trafficking-Related Activity, exploitation, or abuse, we may remove or restrict Content and apply account restrictions immediately pending review.
4.4 Substantive response. We aim to provide a substantive outcome within 7 calendar days of acknowledgement, unless the matter is complex, requires additional information, or is subject to legal constraints. Where additional time is required, we will inform you of the delay and, where feasible, the reason.
5. Outcomes. Following review, the Company may:
a. remove or restrict Content;
b. restrict features, communications, or access;
c. suspend or terminate Accounts;
d. preserve logs and relevant evidence; and/or
e. escalate the matter to appropriate authorities or relevant third parties (including payment or platform partners), where appropriate or required.
6. Appeals: If you disagree with an enforcement decision affecting your Account or Content, you may submit an objection as described in Clause "Moderation and Enforcement of the Customer" Terms and Conditions. Submitting an objection does not automatically reinstate removed Content or restore access during the review.
7. False reports and misuse. Knowingly submitting false, harassing, or abusive Reports may result in enforcement action, including suspension or termination of Accounts.
8. Privacy and data protection. We handle Reports in accordance with applicable data protection law and our Privacy Policy. We collect and use only the information necessary to assess and respond to Reports, and we may retain relevant logs and records for security, audit, and legal compliance purposes.
9. Emergency guidance. If you believe someone is in immediate danger, contact your local emergency services immediately. Our reporting channels are not a substitute for emergency response.
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