Anti-Slavery and Human Trafficking Policy
1. Purpose
LuckyLove.AI ("LuckyLove", "we", "us", or "our") is committed to respecting human rights and preventing modern slavery, human trafficking, forced labour, servitude, and other forms of exploitation in connection with our business and Services.
We do not tolerate slavery, human trafficking, forced labour, or the exploitation of people in any form.
This Policy describes the principles and measures we apply to our operations, workforce, suppliers, service providers, and use of the LuckyLove platform.
2. Scope
This Policy applies to:
- our employees;
- contractors and consultants;
- suppliers and vendors;
- technology and infrastructure providers;
- AI and content-related service providers;
- payment and customer-support providers;
- business partners; and
- other third parties acting on our behalf or providing services to LuckyLove.
We expect relevant business partners and service providers to maintain standards consistent with this Policy and applicable laws concerning modern slavery and human trafficking.
3. Our Business Model
LuckyLove provides AI-powered companion and entertainment services.
LuckyLove AI Companions are software systems and fictional characters. They are not human beings, human performers, or real-world companions.
Our Services are designed to generate and provide AI-generated text, images, audio, video, and other digital content.
We do not use human performers to portray AI Companions within the Services unless expressly disclosed otherwise.
We do not permit the LuckyLove platform to be used to facilitate human trafficking, forced labour, slavery, sexual exploitation, or the commercial exploitation of real people.
4. Prohibited Conduct
LuckyLove prohibits the use of its Services to facilitate or promote:
- slavery or servitude;
- forced or compulsory labour;
- human trafficking;
- debt bondage;
- exploitation of workers;
- recruitment or transportation of people for exploitative purposes;
- sexual exploitation involving trafficking or coercion;
- exploitation of minors;
- coercive or abusive commercial sexual activity;
- the sale or purchase of persons;
- threats, force, deception, or coercion used to exploit another person; or
- any other conduct prohibited by applicable anti-trafficking or forced-labour laws.
Attempts to circumvent these restrictions are also prohibited.
5. Protection of Minors
LuckyLove is an adult-only service. Users must satisfy the applicable minimum age requirement to access the Services.
We do not knowingly permit the use of our Services for the exploitation or sexualization of minors. Content or activity involving the sexual exploitation of minors is strictly prohibited.
Where we identify activity that may involve child exploitation or trafficking, we may take immediate enforcement action and, where required or appropriate, report the matter to relevant authorities or competent organizations.
Our approach to age assurance and child safety is described in our applicable Safety and Age Assurance policies.
6. Platform Safety and AI Safeguards
Because LuckyLove operates an AI-powered platform, we use technical measures designed to prevent the Services from being used for prohibited or exploitative purposes. Depending on the feature and circumstances, these measures may include:
- automated prompt filtering;
- content classification;
- automated output moderation;
- detection of prohibited requests;
- blocking or restricting certain generations;
- account restrictions;
- abuse detection;
- security monitoring;
- investigation of reported violations; and
- escalation of serious safety matters.
These systems are intended to reduce the risk of misuse but cannot guarantee that every prohibited attempt will be detected.
We may modify or strengthen our safety controls as risks, technologies, and applicable legal requirements evolve.
7. Real-Person Exploitation
LuckyLove does not permit users to use the Services to facilitate the exploitation, trafficking, coercion, or abuse of real people. This includes attempts to create or distribute content intended to facilitate:
- trafficking;
- coercive sexual exploitation;
- forced labour;
- commercial exploitation of a person without their consent;
- recruitment for exploitative purposes; or
- other conduct involving the exploitation of real individuals.
Where applicable, such conduct may also violate our Terms of Service and Content Moderation Policy.
8. Employees and Contractors
We expect our employees, contractors, and consultants to respect applicable human-rights and labour standards. We do not permit:
- forced labour;
- involuntary labour;
- unlawful child labour;
- trafficking;
- threats or coercion used to obtain labour;
- retention of identity documents for the purpose of controlling a worker;
- unlawful restriction of freedom of movement; or
- other forms of modern slavery.
Employment and contracting relationships should be based on applicable law, appropriate agreements, and freely given participation.
9. Suppliers and Business Partners
We recognize that modern slavery and forced-labour risks may arise within global supply chains. Relevant suppliers and business partners may include:
- cloud and hosting providers;
- AI infrastructure providers;
- content and moderation providers;
- payment providers;
- customer-support providers;
- professional service providers;
- contractors; and
- other technology or operational partners.
We seek to work with organizations that comply with applicable laws and maintain appropriate standards concerning labour and human rights. Depending on the nature and risk of a relationship, we may use measures such as:
- contractual requirements;
- supplier representations;
- compliance questionnaires;
- risk-based due diligence;
- review of relevant policies or certifications; and
- additional contractual or operational safeguards where appropriate.
The level of due diligence may vary depending on the size, location, nature, and risk profile of the supplier or service.
10. Supplier Requirements
Where appropriate, we expect suppliers and service providers to:
- comply with applicable anti-slavery and human-trafficking laws;
- prohibit forced and compulsory labour;
- prohibit human trafficking;
- comply with applicable minimum-age and child-labour requirements;
- maintain appropriate employment practices;
- provide a mechanism for reporting serious labour concerns; and
- cooperate with reasonable compliance inquiries concerning material risks.
Where a material violation is identified, LuckyLove may take appropriate remedial or contractual action, which may include requiring corrective measures or terminating the relevant relationship.
11. Reporting Concerns
Anyone may report a suspected violation of this Policy. Reports may concern:
- suspected human trafficking;
- forced labour;
- slavery or servitude;
- exploitation;
- child exploitation;
- supplier or contractor practices;
- misuse of the LuckyLove Services for trafficking or exploitation; or
- other conduct that may violate this Policy.
Reports can be submitted to Compliance: [email protected]
For reports concerning content or activity on the LuckyLove platform, Safety / Abuse Reports: [email protected]
Where available, users may also report prohibited content through the reporting tools provided within the Services.
When making a report, please provide enough information to allow us to understand and investigate the concern.
12. Confidentiality and Non-Retaliation
We will handle reports responsibly and, where appropriate, confidentially.
We do not tolerate retaliation against a person who raises a genuine concern in good faith or participates in an investigation.
This does not prevent us from taking appropriate action where a report is knowingly false, fraudulent, or malicious.
13. Investigation and Enforcement
Where we receive a credible report or otherwise identify a potential violation of this Policy, we may investigate the matter. Depending on the circumstances, our response may include:
- reviewing relevant information;
- restricting or suspending an account;
- removing prohibited content;
- restricting access to particular features;
- requiring corrective action from a supplier;
- suspending a business relationship;
- terminating a contractual relationship;
- preserving relevant information;
- seeking professional advice; or
- notifying relevant authorities where required or appropriate.
We will handle investigations in accordance with applicable law and our contractual and privacy obligations.
14. Cooperation With Authorities
Where required by applicable law, LuckyLove may cooperate with law-enforcement, regulatory, or other competent authorities investigating suspected human trafficking, forced labour, exploitation, or related offences.
Any disclosure of personal information will be handled in accordance with applicable law and our Privacy Policy.
15. Training and Awareness
We seek to maintain awareness among relevant personnel regarding:
- modern slavery;
- human trafficking;
- forced labour;
- exploitation risks;
- relevant reporting procedures; and
- responsibilities under this Policy.
The scope and frequency of training may depend on an individual's role and level of exposure to relevant risks.
16. Risk Assessment and Monitoring
We periodically consider modern-slavery and human-trafficking risks associated with our operations and relevant third-party relationships. Risk factors may include:
- geographic location;
- type of services provided;
- workforce model;
- supply-chain complexity;
- industry-specific risks;
- use of subcontractors;
- known regulatory or compliance concerns; and
- information received through reports or investigations.
Where material risks are identified, we may implement additional controls or require appropriate corrective measures.
17. Record Keeping
Where appropriate and permitted by law, we maintain records relating to:
- relevant supplier due diligence;
- reports and investigations;
- compliance actions;
- material incidents; and
- implementation of this Policy.
Records are retained in accordance with our applicable legal, contractual, security, and data-retention requirements.
18. Relationship With Other Policies
This Policy should be read together with our other policies and procedures, including:
- Terms of Service;
- Privacy Policy;
- Cookie Policy;
- Content Moderation Policy;
- Prohibited Content Policy;
- Age Assurance Policy;
- AI Transparency Notice;
- NCII Removal Policy; and
- Complaints and Appeals Policy.
Where another policy establishes more specific requirements for a particular type of conduct, those requirements also apply.
19. Compliance With Applicable Laws
LuckyLove seeks to comply with applicable laws and regulations concerning modern slavery, human trafficking, forced labour, child labour, and human rights.
Depending on the jurisdictions in which LuckyLove operates, this may include applicable requirements under laws addressing modern slavery and supply-chain transparency.
Nothing in this Policy limits or replaces any rights or obligations established by applicable law.
20. Policy Governance
This Policy is owned by VEDMI TECHNOLOGY LTD. Questions concerning this Policy should be directed to [email protected].
We review this Policy periodically and may update it to reflect:
- changes to our business;
- changes to our Services;
- new or emerging risks;
- changes to applicable law;
- findings from investigations or risk assessments; or
- changes to our compliance controls.
21. Contact
For questions or concerns regarding this Policy:
VEDMI TECHNOLOGY LTD
Omonoias, 12, Strovolos, 2008, Nicosia, Cyprus
Compliance, safety reports and privacy: