C05 — Online Safety and Content Reporting Policy
| Field | Value |
| Document ID | C05 |
| Version | 0.1.0 |
| Status | Draft for UK legal review |
| Classification | Public |
| Document owner | Legal / Compliance |
| Effective date | [Effective Date] |
| Review date | [Effective Date] + 12 months |
| Related documents | B01; C01; C03; C04; C06 |
Xila Ltd — Online Safety and Content Reporting Policy
Version 0.1.0 — Draft for UK legal review
Effective date: [Effective Date]
This Policy explains how to report harmful or illegal content on Xila (the "Platform") operated by Xila Ltd ("Xila", "we", "us", "our"), what happens after you report, and how we approach online safety duties under UK law, including the Online Safety Act 2023 ("OSA") where applicable.
Read this Policy with our [Terms of Service (B01)](/legal/terms), [Acceptable Use Policy (C03)](C03-acceptable-use-policy.md), [Community Standards (C04)](C04-community-standards.md), and [Content Moderation and Appeals Policy (C06)](C06-content-moderation-and-appeals-policy.md).
Contact: safety@xila.com (may redirect to support@xila.com until live) · support@xila.com
1. Purpose and scope
Xila includes user-to-user services: social features, messaging, listings, reviews, events, calls and AI-assisted tools. Users can create and share Content. That creates safety risks we must manage responsibly.
This Policy covers:
- what content and conduct we prohibit;
- how to report concerns;
- how we assess and act on reports;
- priority harm categories at a high level;
- cooperation with law enforcement and regulators.
This Policy does not mean all harmful content is illegal, or that Xila guarantees removal of all harmful material.
2. Important distinctions
We treat content and conduct in categories:
| Category | Description |
| Illegal Content | Content or conduct that violates applicable UK law (including certain OSA priority offences where relevant) |
| Prohibited content | Content or conduct forbidden by our Terms and policies but not necessarily illegal |
| Lawful but harmful | Content that may cause harm but is not necessarily illegal or prohibited — we may still restrict it in line with our policies and risk assessments |
| Age-restricted content | Content suitable only for adults; the Platform is 18+ at launch |
Our duties and response processes may differ by category and severity.
3. What we prohibit
You must not use the Platform for Illegal Content or prohibited conduct described in C03 and C04, including at a high level:
- terrorism and violent extremism;
- child sexual exploitation and abuse (CSEA);
- threats to life and serious violence;
- hate offences where content is illegal;
- fraud, scams and financial harm;
- intimate image abuse and voyeurism offences;
- sale of illegal drugs and weapons;
- harassment, stalking and coercive control where unlawful;
- non-consensual sexual content;
- content that amounts to a priority offence under OSA where applicable.
We maintain internal risk assessments and procedures aligned with applicable regulatory guidance. Those internal documents may contain more detail than this public Policy.
4. Priority harms (high-level)
Where OSA or our risk assessments apply, we prioritise swift assessment of credible reports involving:
1. Child sexual exploitation and abuse (CSEA) — including grooming, CSAM, and sexual exploitation of children
2. Terrorism and violent extremism — material promoting or glorifying terrorist acts or groups
3. Threats to life and imminent risk of serious harm — credible threats, including suicide or self-harm risks where urgent intervention may be needed
4. Intimate image abuse — non-consensual sharing of private sexual images or threats to distribute them
5. Serious harassment and hate offences — where content is likely illegal, including racially or religiously aggravated offences where applicable
6. Fraud and financial scams — particularly those targeting vulnerable Users
7. Sale or facilitation of illegal drugs, firearms and other serious criminal facilitation
This list is not exhaustive. We may escalate other serious harms based on context and law.
5. How to report
5.1 In-Platform reporting
The fastest way to report is usually the Report button on posts, profiles, messages (where available), listings, events, calls or other Content. In-Platform tools help us collect context (URLs, user identifiers, timestamps).
5.2 Email and web
You may also contact:
- safety@xila.com (may redirect to support@xila.com until live)
- support@xila.com
Include:
- link or description of the Content / Account;
- category of concern;
- why you believe it is illegal or harmful;
- screenshots or message IDs if available;
- your contact details if you want updates (optional for anonymous reports where supported).
5.3 Intellectual property and privacy
- Copyright / trade mark: use our Copyright and Intellectual Property Policy.
- Data protection rights: see [Privacy Policy (C01)](/legal/privacy) — privacy@xila.com.
5.4 Emergencies
Xila is not an emergency service.
If someone is in immediate danger, contact 999 (UK) or your local emergency number.
If you report imminent risk through our tools or safety@xila.com, we will prioritise review and may take emergency action within our capabilities, but you should still contact emergency services.
6. What happens after you report
We aim to handle reports fairly, consistently and lawfully. Exact steps vary by case, but typically:
Step 1 — Receipt and triage
We log reports and prioritise by severity, credibility, and legal risk. Priority harms (section 4) are escalated urgently.
Step 2 — Assessment
Trained reviewers (and, where appropriate, automated signals) assess whether Content violates law or our policies. We may:
- request more information from the reporter;
- preserve evidence in line with legal and policy requirements;
- restrict visibility pending review for serious cases.
We do not claim to proactively monitor all private communications. Reports are a critical way we learn about harm in private contexts.
Step 3 — Action
Where we find a violation, we may:
- remove or geo-restrict Content;
- add warnings or labels;
- restrict features (posting, messaging, payouts);
- suspend or terminate Accounts;
- refer matters to law enforcement or NGOs (for example, NCMEC/IWF routes for CSEA where applicable);
- notify affected Users as appropriate and lawful.
Where Content does not violate our rules, we may take no action and so inform the reporter where appropriate.
Step 4 — Feedback and appeals
- Reporters may not always receive detailed outcomes, especially where privacy or safety limits disclosure.
- Users subject to enforcement may appeal under [C06](C06-content-moderation-and-appeals-policy.md).
Timelines (good-faith aims)
We aim to acknowledge priority harm reports within 24 hours and other reports within 5 business days, and to complete initial triage within 72 hours for priority harms and 10 business days for standard reports, subject to volume, complexity and legal constraints. These are operational targets, not guaranteed service levels.
7. Illegal content risk management
We maintain governance and risk management proportionate to our service, which may include:
- illegal content risk assessments and updates on material changes;
- reporting and complaints processes;
- moderation and appeals procedures (C06);
- record-keeping of decisions where required;
- senior oversight and training for moderation staff;
- cooperation with Ofcom and other regulators as required by law.
We do not claim perfect detection or prevention.
8. Proactive measures
In addition to user reports, we may use a combination of:
- automated detection signals (for example, spam, malware, known hash matching where deployed);
- keyword and behavioural risk indicators;
- seller/recruitment verification steps;
- rate limits and friction for high-risk actions.
Automated measures are subject to human review for significant enforcement actions where appropriate.
9. Law enforcement and legal requests
We cooperate with law enforcement and regulatory authorities where legally required and consistent with data protection law.
We may:
- preserve and disclose Account and Content information in response to valid legal process;
- proactively report certain illegal content (for example, CSEA) to appropriate bodies;
- restrict disclosure where the law allows and safety requires.
Law enforcement should contact law enforcement contact channel — [TBC] with official documentation. General user reports should use safety@xila.com.
We verify requests before disclosing personal data and document disclosures as required.
10. Users at risk
If we become aware of credible suicide or self-harm risk, we may take measures such as signposting to support resources, limiting harmful content, or contacting emergency services where appropriate and lawful. We are not a mental health provider.
UK signposting examples: Samaritans 116 123; Shout Crisis Text Line — text SHOUT to 85258.
11. Transparency
We may publish periodic high-level transparency information about reports and actions where appropriate (for example, volumes of removals by category). Any public metrics will be accurate and not misleading.
12. Malicious or false reporting
Misusing reporting tools to harass others or submit knowingly false reports violates our Terms. We may restrict Accounts that abuse reporting systems.
13. Children and vulnerable adults
The Platform is intended for users aged 18+. We do not knowingly provide services to children.
If you believe a child is at risk on or through the Platform, report immediately via in-Platform tools or safety@xila.com and contact local authorities or NSPCC (UK: 0808 800 5000) where appropriate.
14. Changes
We may update this Policy to reflect law, regulatory guidance or product changes. Material updates will be notified as described in the Terms.
15. Contact
Safety reports: safety@xila.com (may redirect to support@xila.com until live)
Support: support@xila.com
Post: Xila Ltd, Suite E, Ground Floor, Profile West, 950 Great West Road, Brentford, United Kingdom TW8 9ES
Change history
| Version | Date | Summary |
| 0.1.0 | 2026-07-15 | Initial Online Safety and Content Reporting Policy draft for UK legal review |