Modern Slavery and Human Trafficking Statement
Effective: 28 June 2026 (version 2)
Summary: This is Kismat's voluntary statement on the steps we take to ensure that slavery and human trafficking are not taking place in any part of our business or supply chain. We publish it under the spirit of section 54(1) of the UK Modern Slavery Act 2015 even though we currently sit below the £36 million turnover threshold; we believe meaningful disclosure is the right default for a service that operates at the intersection of online dating and personal safety.
1. Our organization
Kismat is operated by P&P Management GmbH, an Austrian private limited company (FN 648928g, Handelsgericht Wien), Leebgasse 70, 1100 Wien, Austria. We are a small team based primarily in Vienna. Kismat is the company's only product. We do not operate physical premises beyond our registered office, and we do not manufacture or import goods.
2. Our supply chain
Our supply chain is small and mostly digital. The categories of supplier we engage with:
- Cloud infrastructure - hosted Linux infrastructure in the EU, object storage, content-delivery network. All providers in this category are EU-headquartered or subject to EU legal frameworks under our data-processing agreements.
- Payment processing - Apple App Store and Google Play Store handle every consumer transaction. We have no direct relationship with payment-card networks.
- Communication infrastructure - SMTP relay, push notification (APNs / FCM), in-app analytics (privacy-respecting only).
- AI moderation - OpenAI (United States), OpenRouter (United States), Google Gemini (United States), under standard data-processing terms.
- Professional services - Austrian legal counsel, accountants, occasional contractors for design or specialised engineering work.
We do not source physical goods, raw materials, or labour from regions identified by the U.S. Department of State Trafficking in Persons Report or the Walk Free Global Slavery Index as high-risk for forced labour.
3. Policies relevant to modern slavery
Although we do not yet have a stand-alone modern-slavery policy of the type larger organisations publish, the following Kismat policies and practices are relevant:
- Community Guidelines - prohibit human trafficking, sex-for-money solicitation, sugar-dating-style transactional arrangements, and any indicator of coerced participation. See /legal/community-guidelines.
- Notice and Action policy - any user or non-user can flag content that suggests trafficking or exploitation. We commit to triage these reports within 24 hours. See /legal/notice-action.
- Verification - liveness selfie + photo cluster checks at signup raise the cost of operating an account purely as a recruiting funnel.
- Age policy - Kismat is strictly 18+. Underage indicators in signup, photos, or messages trigger an immediate hard block and account review under Austrian StGB section 207a (CSAM) where applicable.
- Procurement - new vendors are reviewed for data-protection terms and supply-chain assurances before we sign. We prefer EU-headquartered providers under EU labour law as a baseline.
4. Risk assessment
We assess risk along two dimensions:
- Operational risk - the chance that a Kismat supplier or contractor uses forced or trafficked labour. We rate this LOW given the digital-services nature of the supply chain and the EU labour-law coverage of our primary vendors. We re-evaluate when we onboard new categories of supplier or expand into new regions.
- User-facing risk - the chance that traffickers attempt to use Kismat as a recruitment or grooming surface. We rate this MEDIUM. The dating-app category is a known target, and we treat the risk as ongoing rather than solved.
5. Due diligence
Concrete steps in financial year 2026:
- Maintain the moderation pipeline that flags trafficking indicators in profiles, photos, and messages, with hard-block thresholds for clear cases and human review for borderline ones.
- Cooperate with Austrian Bundeskriminalamt and Europol when we receive lawful requests related to trafficking investigations.
- Document procurement decisions when we sign new vendors, with a one-page risk note stating what we know about the vendor's labour practices and data-handling.
- Refresh this statement annually.
6. Training and awareness
Every Kismat team member who handles user reports completes an internal briefing on trafficking indicators in dating-app contexts (recruitment patterns, "sugar dating" front-end framing, modelling-agency lures, urgency-driven travel offers). We update the briefing material as new patterns appear in moderation logs.
7. Measuring effectiveness
We track:
- Number of reports flagging trafficking or coerced participation, and median time to triage.
- Number of accounts removed for trafficking-policy violations.
- Number of legal requests received from law enforcement for trafficking-related investigations, and whether we were able to assist.
These metrics will be summarised in the next annual revision of this statement.
8. Approval
This statement is approved by the management of P&P Management GmbH. We will refresh it annually for as long as Kismat is operating, regardless of our turnover. Questions: support@kismat.at.