Copyright, IP and Content Removal Policy

1. Purpose

This policy governs the creation, generation, and publication of AI-generated content on the angels.space digital entertainment platform (the “Platform”) and the website located at https://angels.space (the “Website”), operated by Aratian Limited (“Company”, “we”, “us”). The policy sets out the standards and controls that must be adhered to ensure that content generated on the platform and as offered through the Services does not infringe the copyright, image rights, personality rights, or other intellectual property or privacy rights of any living individual, and that it complies with the Cyprus Copyright and Related Rights Law of 1976 (59/1976) (“Copyright Law”) and related laws and EU regulations as applicable from time to time.

2. Scope

This policy applies to all AI-generated content made available to users through the Services being offered and to which they subscribe. The Company and any third-party providers, developers, or contractors involved in the content generation pipeline are responsible for compliance with this policy.

3. Prohibition on Infringing Content

The Company shall not knowingly generate, publish, or make available content that:

• reproduces, incorporates, or is substantially derived from copyrighted material owned by a third party without a valid licence or legal basis for use;
• is intentionally created to resemble, depict, or evoke the likeness, image, voice, performance, name, or identifiable physical characteristics of any real person, whether living or, where legally protected, deceased, without that person’s explicit consent and appropriate usage rights; or
• otherwise infringes the intellectual property, publicity, or personality rights of any third party under applicable law.

4. Deepfakes

Cyprus law prohibits making available to the public a deepfake imitation of a person’s performance, or of their personal physical characteristics, without that person’s express consent. This protection is not limited to living individuals.

This applies irrespective of the sexual or adult nature of the content. If anything, the adult context raises the standard of care expected, given the heightened risk of harm to any individual who is unintentionally or deliberately depicted.

Where a valid complaint or internal concern regarding deepfake resemblance to a real person arises, the Company shall act promptly to review and, where warranted, remove the content, consistent with its general obligations under Cyprus copyright and relevant laws.

5. Consent-Based Exception

Where the Company has obtained explicit, documented consent and appropriate usage or performance rights from a real individual to generate or maintain an AI-based likeness, performance imitation, or depiction of their personal physical characteristics, such content shall be clearly logged and tracked internally, with supporting documentation (including proof of identity, scope of consent, and duration) retained for as long as such consent remains valid.

6. Content Generation Controls

The Company shall implement and maintain reasonable technical and procedural safeguards in its content generation process to minimise the risk of unintentional resemblance to real, living (or recently deceased) individuals, including but not limited to:

• No real person is depicted. Every Angel on the Platform is a wholly fictional, AI-generated persona with no counterpart outside the Platform. Content is produced by the Company’s internal content team under a standing instruction that no real, identifiable individual is to be depicted, imitated or evoked. The Platform itself performs no image or video generation.
• Admin-only content pipeline. Finished content enters the Platform through a single machine-authenticated publishing route, and every other content-writing surface is restricted to the Company’s administrators. No user of the Platform can publish, or cause to be published, content on an Angel’s profile, in a feed, in stories, or in the Company’s administrator-managed content gallery.
• Zero tolerance for impersonation. Impersonation of any real person is prohibited without exception, both in the content the Company publishes and in the conduct of users under the Terms of Service. Reports of impersonation sent to the intake address in Section 8 are treated as urgent.
• Review and removal on report. Where a resemblance to a real individual is identified, whether internally or through a report, the content is reviewed by the Company and, where the report is verified and the content falls within the scope of this policy, it is removed in accordance with Section 8.

The Company does not operate automated likeness matching against real individuals, public figures, or any reference set, and does not run automated scanning of published content. The commitment that no real person is depicted is a process and policy commitment of the Company’s content team rather than an automated check performed by the Platform, and identification of an unintended resemblance therefore depends on internal review and on the reports made under Section 8.

7. Unintentional Resemblance

Notwithstanding the safeguards above, the Company acknowledges that AI-generated content may, on rare occasions, unintentionally resemble a real individual due to the nature of generative AI systems. Any such resemblance is unintended and not a deliberate reproduction of a specific person’s likeness, performance, or physical characteristics. Where such resemblance is identified, whether internally or through a user or third party, the content shall be removed or amended promptly in accordance with Section 8 below.

8. Content Removal Process

Where a request or report is received, whether from a user, a third party, or a real individual who believes that content available on the Services resembles them or another identifiable person, the following internal process shall apply:

• Receipt of request: requests may be received by e-mail to abuse@angels.space, or by post to Aratian Limited, Andrea Syngrou 32A, Lakatameia 2300, Nicosia, Cyprus.
• Verification: to ensure the accuracy and legitimacy of a removal request, the Company’s management may request that the requester provide adequate evidence of their identity or their relationship to the person depicted in the content. This safeguards against fraudulent or unfounded requests while ensuring genuine concerns are addressed appropriately.
• Review: upon receipt of a request (and any supporting verification), the Company’s management shall review the content in question to determine whether it constitutes a deepfake imitation or unintentional resemblance requiring removal under the provisions of this policy.
• Removal: where the request is verified and the content is confirmed to fall within the scope of this policy, the content shall be removed from the digital platform within 48 hours, and the outcome logged for internal record-keeping.
• Confidentiality: all removal requests and related communications shall be treated as strictly confidential. No personal information or details of a request shall be disclosed to any third party without explicit consent, unless required by law.
• Escalation: where a request raises broader concerns, for example a pattern of resemblance to a specific individual, or a request involving a public figure or potential legal claim, the matter shall be escalated to the Company’s management in accordance with Section 9 below.

9. Review and Escalation

Any concerns regarding potential copyright, personality rights, or deepfake-related infringement identified by staff or contractors shall be escalated immediately to the Company’s management for review. The Company shall maintain a log of all such escalations, the review outcome, and any remedial action taken, including the timeframe within which content was reviewed and, where necessary, removed.

10. Third-Party Providers

Where content generation relies on third-party AI models, tools, or datasets, the Company shall ensure that its agreements with such providers include appropriate warranties, indemnities, and compliance obligations regarding intellectual property, personality rights, and deepfake-related infringement under applicable Cyprus and EU law.

11. Policy Review

This policy shall be reviewed periodically, to ensure continued compliance with applicable copyright, deepfake, data protection, and personality rights law in all relevant jurisdictions, including any developments in Cyprus or EU legislation relevant to AI-generated content.