1

Introduction & The Sanctuary Promise

Who we are and what we stand for

Welcome to The Sanctuary. We are a survivor-led platform dedicated to digital safety, providing a secure environment with zero tolerance for predators. This platform is operated with full legal transparency. The Administrator is identified by both her chosen name (Jessica) and legal business entity (John Shinsky) to ensure a singular chain of accountability.

Medical Disclaimer: We are an open door for support, but we are not counsellors, psychiatrists, or medical professionals. We do not provide mental health treatment or clinical advice. Our mandate is focused on platform safety, infrastructure, and legal accountability.

2

Jurisdiction & Legal Structure

Where we operate and under what law

The Service's physical infrastructure, including all data storage servers and primary hosting facilities, is located within the Commonwealth of Australia, secured using custom configurations and hardened access protocols. We operate under strict Australian regulatory frameworks governing online safety and privacy, including the Online Safety Act 2021 and the Privacy Act 1988.

The platform operator resides in Oregon, United States. By accessing the Service, US-resident users explicitly acknowledge that data handling and retention are subject to the physical jurisdiction of Australia, and provide express, informed consent for the cross-border transfer and storage of their data. Any legal proceeding not subject to mandatory arbitration shall be brought exclusively in the state or federal courts of Multnomah County, Oregon.


3

Identity Verification & Fraud Prevention

Keeping predators out from the start

To keep our community predator-free, all users must complete identity verification. We operate under a strict "Ringfence and Destroy" protocol for all identity-related documents, ensuring your sensitive data is never stockpiled or exposed. You may choose between:

OPTION A Automated: A secure link to complete instant verification via Stripe Identity. Your identity documents are processed solely for the immediate verification event and are not stored on Stripe's servers or our own.
OPTION B Live Vouch: A brief manual video call via 3CX with the Administrator. We only need to see your face, name, and date of birth. We actively encourage you to cover your address and any ID numbers. No recordings are kept.
OPTION C Age Estimation: Available to those who appear to be 40 or older. A live Administrator will visually assess your age via a brief call on the platform. No ID is required. No recordings are kept.

4

Verified vs. Unverified Users

Under 18 safeguards

Our platform categorises accounts into Verified and Unverified tiers. Anyone under the age of 18 is strictly classified as an Unverified User. Because we must account for the reality that individuals may misrepresent their age during sign-up, all Unverified accounts operate under mandatory, non-negotiable safety filters designed to prevent grooming and exploitation:

  • Numeric Entry Restricted: To prevent the sharing of phone numbers, physical addresses, or identifiable digits, no more than two consecutive digits may be sent in any communication.
  • Profanity Filtering: Global profanity and predatory keyword filters are permanently active on all Unverified accounts.
  • Feature Restrictions: Voice and video messaging capabilities are entirely disabled to ensure bad actors cannot bypass text-based safety measures.

5

Account Security & Manual Processes

Human oversight over automated convenience

At The Sanctuary, we prioritise the safety of your data over sheer convenience. Critical account actions are managed manually to minimise the risk of automated exploits or unauthorised access.

  • Manual Password Resets: Password reset links are not automatically generated by a script. Your request is manually reviewed and a reset link is sent directly by the Administrator.
  • Manual Verification Dispatch: Secure links for Stripe Identity verification (Option A) are also generated and dispatched manually upon request.
  • Timeframes & Verified Sender: Please allow up to 24 hours, though requests are typically processed much sooner. All official correspondence will only ever be sent from: [email protected]

6

Privacy & Data Minimisation

We collect only what we need

We restrict data collection to the absolute minimum required to provide a secure social platform and enforce our Community Standards:

  • Personal Identification: Your first and last name, collected during sign-up and verification, is permanently tied to your account for accountability.
  • Account Information: Necessary secure credentials.
  • Communication Data: Messages, media, and comments.
  • Technical & Connection Metadata: IP addresses, browser fingerprints, and the exact dates and times of your account logins and logouts.
Data Retention: Safety metadata is retained for 730 days. Deleted content undergoes a 7-day soft-delete before a 30-day hard deletion process.

7

Encrypted Peer-to-Peer Communications

Secure voice and video on our own infrastructure

For secure voice and video interactions, The Sanctuary utilises a custom-hosted instance of MiroTalk, deployed directly within our own sovereign Australian infrastructure. This removes reliance on external or third-party communication providers.

  • Self-Hosted & Private: By operating MiroTalk strictly on our own servers, we retain complete operational control over the signalling environment, ensuring external entities cannot access your connection data.
  • Peer-to-Peer Architecture: Calls are built on a secure P2P framework. Media streams are transmitted directly between participants, meaning the content of your conversations is end-to-end encrypted and does not pass through our media servers.
  • Zero Media Retention: We do not record, intercept, monitor, or store the contents of your voice or video calls. Only the essential connection metadata required to initiate the call is logged.

8

Community Standards & Message Filtering

The Grandmother Rule

The Sanctuary enforces the "Grandmother Rule" - if you would not say it in front of your grandmother, do not say it here. This is the standard we hold all content to.

A note on message filtering: Automated safety filters scan direct messages to help prevent grooming and abuse. These filters act passively, blocking or flagging content automatically. Flagged content may be reviewed by the Administrator as part of the moderation process. Moderation decisions are made by the Administrator or through the user reporting system. By using the platform, you acknowledge that your messages may be filtered and reviewed for safety purposes.

Prohibited Content: We strictly prohibit child exploitation material, non-consensual intimate imagery, harassment, stalking, violence, credible threats, extremist propaganda, drug trafficking, fraud, and malicious software. Breaches result in immediate removal and permanent termination of access.

Hate Speech: Hateful content is flagged for human review. We believe in considered responses rather than knee-jerk automated removal, but repeat or serious violations will result in action.


9

Mandatory Reporting & Law Enforcement

We act, we do not wait

We do not wait. We document all evidence and coordinate directly with law enforcement. We do not sell or trade your personal information. We only disclose information to third parties:

  • In response to a valid warrant or subpoena issued by a court of competent jurisdiction.
  • To prevent an imminent threat to life or physical safety.
  • To fulfil mandatory reporting obligations to the Australian Centre to Counter Child Exploitation (ACCCE), the National Center for Missing & Exploited Children (NCMEC), and relevant federal law enforcement regarding any suspected child exploitation material.

10

Reporting, Moderation & Appeals

Fair process for everyone

Users may report harmful content through the platform. Reports are reviewed manually and actioned within 24 hours. If you believe a mistake has been made or you have triggered a false positive, you may contact the Administrator to lodge an appeal. The Administrator is glad to hear your side and correct mistakes; however, repeated abuse of the appeals process will result in a denial of further reviews.


11

Dispute Resolution & Binding Arbitration

How disagreements are resolved

The platform is provided on an "as is" basis. Any dispute arising under this agreement shall be resolved through binding arbitration in Portland, Oregon, administered by the American Arbitration Association. The user hereby waives the right to a trial by jury and the right to participate in any class-action litigation or representative proceeding.


12

Privacy Enquiries & Complaints

Your rights under Australian privacy law

For privacy-related enquiries, data access, deletion requests, or regulatory matters, please contact the Privacy Officer/Administrator. All correspondence will be handled in accordance with the Privacy Act 1988 (Cth). If you are not satisfied with our response to a privacy complaint, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC).

/s/ Jessica Shinsky
Platform Administrator & Sole Appeals Authority
Legal Name: John Shinsky
Contact: [email protected]
Executed: 22 March 2026