Introduction:

This Anti-Fraud Policy applies to the “End User,” defined as the individual or entity entering into a contractual agreement with us by accepting our Terms of Use and providing content for distribution on Digital Service Providers (DSPs). “We” or “Us” refers to the service provider, Too Lost.

This policy serves to:

1. Define “fraud” and related activities.
2. Outline the responsibilities of End Users in preventing fraudulent behavior.
3. Offer guidance for addressing potential fraud when flagged by us, a DSP, or a third party.
4. Clarify the investigative process for fraud-related incidents.
5. Protect rights holders impacted by fraudulent activities.

This document should be reviewed in conjunction with the following:

• Terms of Use
• Privacy Policy

Definitions:

• End User: The individual or entity contracted with Too Lost to utilize the platform.
• User Account: The account owned and managed by the End User.
• Fraud: Unauthorized use of copyrighted materials (copyright infringement), violations of intellectual property laws, misuse of artist, band, or label names, use of bots for generating fake clicks (click fraud), or any action that violates our Terms of Use or our agreements with DSPs.

Policy Overview:

Fraud of any kind is unacceptable to us because it harms not just DSPs and us, but also other creators who lose revenue or face reputational damage. It can also jeopardize our relationships with DSPs, affecting other End Users who rely on our services.

Our primary goal is to detect, prevent, and eliminate fraudulent activity. Any suspicion of fraud will be thoroughly investigated and addressed promptly.

DSP Actions:

Many DSPs use algorithms combined with human review to detect suspicious or fraudulent content. If fraudulent streams are identified, the DSP may remove the content and withhold revenue generated from these activities.

Our Fraud Prevention Efforts:

We actively monitor sales data, artist profiles, social media presence, and user information to identify any irregularities. All content, both new and existing, undergoes fingerprinting to prevent unauthorized uploads or duplication of existing copyrighted materials.

Additionally, we have implemented strict quality control processes to identify misleading metadata or other forms of “musical spam.”

Handling Suspected Fraud:

If fraudulent activity is suspected, we will engage with the End User and issue warnings based on a 3-strike policy. If necessary, we may block the End User’s account, especially in cases where suspicious activity persists.

Revenue associated with fraudulent content may be withheld. Blocked accounts can only be reactivated after the End User follows the proper verification protocol.

Consequences of Fraud:

If the End User is found to have breached our Terms of Use, we reserve the right to terminate the contract. Any DSP earnings generated through fraudulent activities may be withheld, and we may deduct any legal or associated costs from future payouts.

Severity Tiers and Strike System:

We categorize potential fraud cases into three tiers:

• F0 (Critical): Severe issues related to user accounts, such as fake information or unauthorized content.
• F1: Suspicious activity such as click fraud, including sudden surges in streams or sales with no legitimate social media presence.
• F2: Issues involving musical spam, misleading metadata, or copyright violations.

Strike Policy:

For F1 and F2 issues, we apply a 3-strike policy:

• Strike One: The End User is notified, the suspicious content is taken down, and a warning is issued.
• Strike Two: The End User is informed again, content is removed, and the account is warned of impending blockage if another strike occurs.
• Strike Three: The End User’s account is blocked, all content is removed, and royalties are held in escrow for up to 5 years.

Blocked Accounts:

If an End User does not comply with our requests for additional information, their account will be blocked, and revenue will be held in escrow. Blocked users will lose access to our platform and services, and if no resolution is reached, all content will be removed.

Royalties for flagged content will remain in escrow for up to 5 years, during which time we will investigate claims and distribute funds accordingly. Any remaining funds after this period will be released to the End User if no further claims arise.

Unblocking Accounts:

To unblock an account, End Users must provide complete and accurate information within 5 working days. This may include identity verification documents, artist profile links, or proof of ownership for uploaded content. If the information is verified, the account will be restored.

Resolving Strikes:

End Users can take specific steps to resolve strikes, such as correcting release metadata or providing proof of ownership. If the information provided is sufficient, the strike will be lifted. Otherwise, the strike will remain and further consequences may follow.

Withholding of Royalties:

Royalties connected to fraudulent activities will be withheld for up to 5 years. If the End User proves their account is not fraudulent, funds will be released. If DSPs or other rights holders request a refund due to unauthorized activity, the funds will be used to cover those claims.

Takedown Policy:

Content involved in fraudulent activities will be removed. DSPs may also take down content flagged as suspicious at their discretion.

This policy is designed to ensure transparency, protect creators, and maintain the integrity of our platform. Any End User found violating this policy will face strict penalties, including account termination and withholding of royalties.