Table of Contents:

Introduction

Definitions

Policy Statement

Non-Exhaustive Examples of Fraud and Abuse

Detection and Prevention Measures

Response to Suspected Fraud

Enforcement Framework

Royalty Retention, Escrow, and Documentation

Content Actions

Appeals and Review Process

Remedy for System Error

Cooperation and Disclosures

Governing Law; Precedence

Policy Updates

Contact and Support

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1) Purpose and Scope

UMW Recordings Inc. (“UMW,” “we,” “us”) is committed to maintaining a fair and trustworthy ecosystem for artists, labels, partners, and users. This Anti-Fraud Policy explains how we detect, investigate, prevent, and enforce against fraudulent or deceptive activity across the Services, including activity that may affect distribution, monetization, royalties, analytics, and account integrity.

This Policy applies to all users, including artists, labels, managers, and aggregators using the Services under our Terms & Conditions and related policies.

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2) Definitions

• User: Any individual or entity accessing or using the Services.
• DSP(s): Digital Service Provider(s) such as streaming platforms, music stores, UGC platforms, and similar distribution outlets.
• Royalties: Revenue reported by DSPs and payable to rights holders based on legitimate exploitation and compliant activity.
• Fraud / Fraudulent Activity: Any intentional or negligent act or omission designed to deceive, manipulate, or unlawfully benefit (financially or otherwise), including artificial engagement, misrepresentation, or abuse of systems.
• Fraudulent Content: Content associated with unauthorized rights, misleading metadata, deceptive attribution, artificial engagement, or other manipulation described in this Policy.
• Investigation: Review process using technical, financial, and behavioral indicators, internal logs, DSP reports, third-party tools, and user-submitted documentation.

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3) Policy Statement (Zero-Tolerance)

We maintain a zero-tolerance stance toward fraud. We may suspend, restrict, or terminate accounts; block releases; remove content; hold or claw back royalties; and cooperate with DSPs, rights holders, and authorities to protect legitimate creators and platform integrity.

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4) Non-Exhaustive Examples of Fraud and Abuse

The following are examples (not a complete list):

A. Artificial Streaming / Engagement Manipulation

• Use of bots, click farms, traffic manipulation services, automation loops, or coordinated behavior designed to inflate streams, views, saves, followers, or other metrics.
• Routing activity through misleading VPN patterns, device farms, repetitive short plays, or suspicious “burst” patterns inconsistent with organic listening.

B. Metadata and Identity Misrepresentation

• Misleading use of famous artist names, brands, logos, or likenesses to drive traffic or confuse consumers.
• False credits, fake collaborations, deceptive genre/keywords, or intentionally misleading titles intended to capture searches.

C. Rights / Ownership Fraud (Content Authenticity)

• Uploading content without valid rights (master and/or publishing) or without required licenses/clearances.
• Uploading edited, re-recorded, or disguised versions of protected works to evade detection.
• Using forged, incomplete, or unverifiable rights documents as “proof.”

D. Account, Payment, and Platform Abuse

• Multiple fake accounts, identity spoofing, reseller abuse, evasion of sanctions, or attempts to bypass enforcement measures.
• Abuse of refunds/chargebacks or payment systems.
• Interference with security controls, scraping, reverse engineering, or attempts to compromise systems.

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5) Detection and Prevention Measures

UMW may use a layered approach that includes:

• Automated Monitoring: Anomaly detection for unusual spikes, pattern irregularities, geographic inconsistencies, device fingerprints, and reporting discrepancies.
• Manual Review: Human review of alerts, reports, and high-risk activity; enhanced review for UM3–UM4 cases prior to final enforcement.
• DSP Collaboration: Cross-verification with DSP reports, adjustments, and fraud signals.
• Third-Party Tools: Fingerprinting, machine learning, device intelligence, and anti-fraud systems used to identify suspicious patterns.
• Education: Guidance and notices to help users avoid risky promotion practices.

UMW is not required to disclose sensitive details of detection methods that could compromise platform security; however, we will provide meaningful explanations of the basis for actions whenever feasible.

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6) Response to Suspected Fraud (Investigation Process)

When suspicious activity is detected, UMW may take one or more of the following steps:

1. Immediate Investigation: Review account history, releases, traffic sources, usage logs, DSP reports, and technical indicators.
2. User Notification: We may notify you of suspected fraud and request documentation or explanations.
3. Opportunity to Respond: Users may submit a response and supporting materials (see Section 8).
4. Temporary Measures (Risk Controls): We may impose temporary restrictions such as:
   • payout holds,
   • feature limitations,
   • release delays,
   • distribution suspensions, or
   • provisional content takedowns.

Review Timeline: Temporary measures will be reviewed within a reasonable timeframe, generally not exceeding 60 days, unless extended due to complexity, DSP dependency, legal requirements, or ongoing risk.

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7) Enforcement Framework (Severity Levels UM1–UM4)

UMW uses severity levels to ensure proportional enforcement:

• UM1 — Minor / Correctable Issues
  Example: honest metadata errors, incomplete credits, minor inconsistencies.
  Action: warning + required corrections, possible release delay.
• UM2 — Moderate Deception / Elevated Risk
  Example: repeated misleading metadata, suspicious promo vendors, questionable attribution.
  Action: formal warning, enhanced verification, temporary restrictions, possible payout hold.
• UM3 — Artificial Engagement / Serious Abuse
  Example: clear artificial streaming indicators, manipulative campaigns, coordinated fake activity.
  Action: functionality block, release takedown/hold, royalty freeze, escalated review.
• UM4 — Deliberate or Repeated Fraud / Evasion
  Example: repeated UM3 behavior, forged documents, organized fraud, enforcement evasion.
  Action: account termination, broad distribution blocks, full royalty retention/offset, legal escalation where appropriate.

Escalation Cycle (EC1–EC4)

EC levels describe progressive enforcement steps that may apply within UM2–UM4:

• EC1: Advisory notice + request for correction/verification.
• EC2: Formal warning + temporary restrictions and/or verification hold.
• EC3: Final warning + payout freeze/release block pending documentation.
• EC4: Termination and/or permanent restrictions; content removal; financial adjustments.

Good-Faith Appeals: Users who appeal in good faith will not be penalized merely for appealing.

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8) Royalty Retention, Escrow, and Documentation‍

A. Royalty Holds and Escrow

Royalties suspected of being linked to fraud may be held in escrow for up to 24 months, with biannual reviews. Users may request early reassessment by providing credible evidence.

B. What to Submit to Contest a Hold / Rejection

You may submit one or more of the following (as applicable):

• Master license or proof of ownership (artist/label agreements, producer agreements)
• Publishing license/mechanical clearance for compositions and derivatives
• Signed split sheets
• Chain of title (including sublicenses and territories)
• Original stems/session files or fingerprint-compatible evidence (where relevant)
• ISRC/ISWC/UPC and verifiable metadata
• Authorization letters from the rights holder
• Invoices/receipts evidencing rights acquisition

Insufficient Evidence (by itself): unilateral declarations, screenshots without metadata, unverifiable emails, unsigned or untraceable documents.

C. Set-Off, DSP Adjustments, Chargebacks, and Negative Balances

UMW may offset any amounts owed to UMW (including fraud-related clawbacks, DSP adjustments, penalties, refunds, fines, or chargebacks) against royalties or other sums payable to the user, including across accounts under common control. If a negative balance results, the user remains responsible and must repay within 30 days of notice.

D. Evidence Preservation

UMW may preserve relevant logs, detection reports, and financial records for 36 months from case closure to support audits, enforcement, and legal proceedings, consistent with applicable law and our Privacy Policy.

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9) Content Actions (Blocking, Removal, and Corrections)

UMW may:

• block or delay releases pending verification,
• remove or disable access to content linked to fraud,
• require metadata corrections,
• notify DSPs or partners of confirmed abuse signals,
• restrict future submissions.

Copyright / DMCA: ... handled under our DMCA / Copyright Policy:

https://www.umwrecordingsinc.com/dmca

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10) Appeals and Review Process

• Appeal Window: Users may submit a formal appeal within 15 business days of notification.
• Acknowledgment: We aim to acknowledge receipt within 2 business days.
• Update: We aim to provide a substantive update within 15 business days.
• Resolution: We aim to resolve standard cases within 30–45 days, subject to complexity and third-party cooperation.

UM3–UM4 actions are subject to human review prior to final enforcement.

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11) Remedy for System Error / False Positives

If UMW determines that an enforcement action was made in error:

• we will restore access and/or distribution where feasible,
• return legitimately earned royalties that were incorrectly held (subject to DSP reporting/settlement timing),
• and document corrective measures internally to reduce recurrence.

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12) Cooperation and Disclosures

UMW may share relevant information with DSPs, payment processors, vendors, rights holders, and law enforcement/regulators when:

• required by law,
• necessary to prevent fraud, enforce policies, or protect rights and safety,
• necessary to resolve disputes or respond to legal process.

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13) Governing Law; Precedence

This Policy is governed by the laws of the Republic of Ecuador. Disputes related to this Policy shall be resolved in the competent courts of Guayaquil, Ecuador, unless mandatory consumer rules apply.

Precedence: In the event of conflict, the following order applies:

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(1) Terms & Conditions,

(2) Anti-Fraud Policy,

(3) Acceptable Use Policy,

(4) other published guidelines.

Specific written agreements with UMW or DSPs may supersede where expressly stated.

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14) Policy Updates

We may update this Policy to reflect legal, technical, or operational changes. Updates are effective upon posting on our website with a revised “Last Updated” date.

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15) Contact and Support

• Email: antifraud@umwrecordingsinc.com
• Phone: +593 96 801 6285
• Live Chat: Available during business hours

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