Human Rights Statement

Version 1.0 | Last Updated: 22 April 2026 | Effective Date: 22 April 2026

1. Scope

This Statement applies to SocialGryd Limited, our subsidiaries, and our employees, officers, and contractors. We also expect our sub-processors, partners, brands, creators, and other business counterparties to respect these principles and to address adverse impacts they cause or contribute to, consistent with our contractual terms.

2. Principles

• UN Guiding Principles on Business and Human Rights (2011). We adopt the three-pillar framework: the state duty to protect, the corporate responsibility to respect, and access to remedy for victims.
• International Bill of Human Rights. We respect the rights recognised in the Universal Declaration of Human Rights and the two International Covenants.
• ILO Core Labour Standards. We uphold freedom of association, freedom from forced and child labour, and non-discrimination.
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (2023 update).
• Santa Clara Principles on Transparency and Accountability in Content Moderation.
• UN Principles on Protection of Journalists and Human Rights Defenders.
• Children's Rights. UN Convention on the Rights of the Child, including as reflected in the UN Committee on the Rights of the Child's General Comment No. 25 on children's rights in relation to the digital environment.

3. Salient Human Rights Risks

We identify the following human-rights risks as most salient to the SocialGryd product and will address them through due diligence (Section 4):

• Freedom of expression — risk of over-removal or wrongful restriction of lawful speech, especially in politically sensitive contexts.
• Freedom of assembly and association — risk of disruption to lawful organising or advocacy, especially in jurisdictions where this is targeted by state actors.
• Right to privacy — risk of excessive data collection, opaque profiling, or disclosure to authorities without adequate safeguards.
• Right to non-discrimination — risk of algorithmic bias or inconsistent moderation affecting protected groups.
• Rights of the child — risk of exposure to harmful content, grooming, or age-inappropriate profiling.
• Physical security and safety — risk of off-platform harm enabled by on-platform coordination (doxxing, stalking, targeted harassment).
• Right to remedy — risk that users affected by moderation or data decisions cannot access effective redress.
• Labour rights — risks within our workforce, contractors (including content moderators where engaged), and supply chain.

4. Human-Rights Due Diligence

Consistent with UNGP 17–21 and the OECD Due Diligence Guidance, our due diligence process includes:

• Assessment. We assess human-rights impacts of new features, policies, and sub-processors through product review, Data Protection Impact Assessments, and human-rights impact assessments where indicated.
• Integration. We integrate findings into product, engineering, policy, legal, and operations decision-making.
• Tracking. We track performance through metrics in our Transparency Report, including moderation actions, notices received, appeals upheld and overturned, and legal-process requests.
• Communication. We communicate what we do and what we learn in this Statement, the Transparency Report, and public updates where appropriate.
• Remediation. Where we cause or contribute to an adverse impact, we provide or cooperate in remediation (see Section 6).

5. Engagement with Stakeholders and Rights-Holders

We engage, or commit to engage as our scale justifies, with:

• Users and member communities, including through in-app surveys, feedback channels, and appeals data
• Civil-society organisations working on digital rights, child safety, LGBTQ+ rights, and journalist protection
• Regulators and oversight bodies, including Data Protection Authorities, Digital Services Coordinators, eSafety regulators, and the European Board for Digital Services
• Trusted Flaggers under DSA Article 22
• Our sub-processors, partners, brands, and creators on an ongoing contractual basis

6. Grievance Mechanism and Remedy

We provide the following grievance channels:

• In-app reporting and appeals. Any user may report content and appeal a moderation decision via in-app tools; appeals are reviewed by a human who was not the original decision-maker.
• Content moderation appeals. Statements of Reasons are issued for all restrictions under DSA Article 17; appeal routes are described in our Terms Section 18.
• Data rights. Access, correction, deletion, objection, and portability rights under GDPR and equivalent laws can be exercised through privacy@socialgryd.com or dpo@socialgryd.com.
• Human-rights concerns. Stakeholders, rights-holders, and affected individuals may raise human-rights concerns with us at legal@socialgryd.com with the subject "Human Rights Concern". We acknowledge within 7 days and substantively respond within 30 days. Concerns are triaged to Legal, Trust & Safety, or Privacy as appropriate.
• External remedy. Where our own processes do not resolve a concern, affected individuals may refer to out-of-court dispute settlement under DSA Article 21, to competent data-protection authorities, to OECD National Contact Points, or to the courts.

7. Transparency

We publish regular transparency data at /transparency, covering moderation actions, user notices, legal-process requests, and (where applicable) DSA-specific disclosures. We aim to add human-rights-specific indicators as our scale and practice mature.

8. Government Requests and State Actors

We handle government and law-enforcement requests under our Law Enforcement Guidelines. We push back on overbroad, politically motivated, or human-rights-affecting requests, notify affected users where permitted by law, and seek judicial oversight where appropriate. We do not voluntarily disclose user data for political or opinion-based purposes.

9. Business Relationships and Leverage

Where we are linked to an adverse human-rights impact through our sub-processors, partners, brands, or creators, we will use the leverage we have through contracts, technical integration, and commercial relationship to encourage the prevention or mitigation of the impact, and in serious cases we will disengage.

10. Children's Rights

We implement the UK Age-Appropriate Design Code (Children's Code) principles globally where feasible and commit to ongoing DPIAs for features affecting minors. Our approach to child safety is set out in our Child Safety Standards. The minimum age on the Platform is 16 (higher in certain jurisdictions — see Privacy Policy Section 22).

11. Governance

Senior accountability for human-rights performance rests with the founder and leadership team. Operational responsibility is distributed across Trust & Safety, Privacy (DPO), Legal, and Engineering. We review this Statement at least annually.

12. Contact

• Human-rights concerns: legal@socialgryd.com
• Data Protection Officer: dpo@socialgryd.com
• Safety and abuse: report@socialgryd.com
• SocialGryd Limited, Narva mnt 5, Kesklinna linnaosa, Tallinn, Harju maakond 10117, Estonia