govno.world Terms of Service

📝 DRAFT (v0.1). NOT legal advice and not the final text. Before publication this requires: (1) review by qualified counsel against the actual legal entity and jurisdictions; (2) localization into the languages of the markets served; (3) completion of the […] placeholders. The document covers app-store and DSA requirements — see app-store-compliance.md, store-publication-docs.md.

Version: 0.2 · Date: 09.09.2026 · Operator: SOWITA LLP, BIN 231040004646, registered address: 7 Pavlodarskaya Street, Zhetysu District, Almaty 050016, Republic of Kazakhstan (the "Operator", "we"). Company details — Imprint.

App: Grumzo (App Store / Google Play, bundle identifier app.grumzo) · Service: govno.world · Operator: SOWITA LLP (Republic of Kazakhstan).

1. General Provisions and Acceptance

1.1. These Terms of Service (the "Terms") govern your use of the govno.world application and service (the "Service") — a pseudonymous social network for short text posts ("complaints"), comments and reactions. Uploading photos or files is not available in the Service.

1.2. By using the Service, you accept these Terms. If you do not agree, do not use the Service. Creating an account and any publication of user content are possible only after you have expressly accepted these Terms (this step cannot be skipped).

1.3. 18+ age requirement. The Service is intended for persons aged 18 or older. By registering, you confirm your age. The Service is not directed at children.

1.4. The following are integral parts of these Terms: the Privacy Policy, the Community Guidelines, and the CSAE Standard. The Service has no purchases and no subscriptions (see §7), so the stores' payment rules do not apply to you.

2. Account and Pseudonymity

2.1. Registration uses an email address and a chosen username. Pseudonymity: your username is publicly visible (or "Anonymous" for anonymous posts), but the Operator stores an author identifier for the purposes of moderation, appeals, and compliance with the law.

2.2. You are responsible for keeping your access credentials secure and for all activity under your account. One person, one account (no abuse of multiple accounts).

2.3. Account deletion. You may initiate deletion of your account and associated data at any time within the app (and also via the deletion request page). Some data may be retained where required by law (for example, CSAM cases) — see the Privacy Policy.

3. Content Rules and "Zero Tolerance"

3.1. Zero tolerance for objectionable content and abusive users. In particular, the following are prohibited: child sexual abuse material (CSAM) and any sexual content involving minors; illegal content; threats of violence; hate speech and discrimination; harassment, bullying, and defamation/degradation of specific individuals; sexually explicit 18+ content outside the rules; spam and fraud; and infringement of third-party rights. The full list is set out in the Community Guidelines.

3.2. You publish content at your own responsibility and confirm that you hold the rights to it and that it does not violate the law or these Terms.

3.3. License. You retain the rights to your content. By publishing it, you grant the Operator a non-exclusive, royalty-free, worldwide license to store, reproduce, display, adapt (previews, compression), and moderate the content solely for the operation of the Service and compliance with the law. The license terminates when the content is deleted, except for copies that must be retained by law or for safety reasons.

4. Moderation (Transparency — DSA Art. 14)

4.1. Content undergoes moderation. We use automated tools (AI classifiers, including a third-party text-moderation service) and human review by moderators. The tools we use and their respective roles are described in the Privacy Policy; the transfer of content to third-party processors is described there as well.

4.2. The text of posts and comments is reviewed before publication (synchronously, fail-closed: if the check fails, publication does not occur). The Service accepts no user content other than text.

4.3. We are entitled to remove content, restrict access, issue warnings, and suspend or block accounts that violate these Terms or the Community Guidelines, including without prior notice in the case of serious violations.

4.4. Reports and appeals. You can report content or a user (report) and block a user (block) using the app's tools. We respond to reports promptly (target — within 24 hours for clearly objectionable content). Moderation decisions may be appealed — the procedure is described in the app and the Community Guidelines.

5. Prohibited Conduct

You are prohibited from: circumventing moderation, filters, and bans; mass or automated posting (spam, bots); harvesting user data (scraping); impersonating others; interfering with the operation of the Service (load attacks, exploits, reverse engineering beyond what is permitted by law); and using the Service for unlawful purposes.

6. User Safety and Crisis Content

6.1. The Service is not a psychological, medical, or emergency service and is not a substitute for one. If life is at risk, contact the emergency services immediately.

6.2. Where there are signs of self-harm or suicide, we may display a supportive card with contact details for crisis helplines — this is a gesture of care, not a block and not a medical service.

6.3. CSAM: zero tolerance. We scan, remove, and report detected material to NCMEC and/or the competent authorities, retain data as required by law, and assist investigations (see csae-runbook.md).

7. Money: no paid features, voluntary donations only

7.1. The Service is entirely free. There are no paid features, no subscriptions and no in-app purchases. No capability of the Service sits behind a paywall.

7.2. A donation is a voluntary gift. You may support the Service with a donation on a separate page in your browser (https://govno.world/donate). The recipient of the funds is SOWITA LLP (details in the Legal Notice); the same name appears on your card statement. A contribution is not a charitable donation and does not qualify for a tax deduction. It is a gratuitous gift: in return you receive no goods, services, digital content, features, badges or advantages in the Service — neither immediately nor later. A donation is not a purchase and creates no reciprocal contract between us.

7.3. Payment is handled by a third-party payment processor on its own page. We neither receive nor store your card details. The processor's own terms and privacy policy govern the payment itself.

7.4. Refunds. As nothing is given in return, a donation is as a rule non-refundable; if a payment was made in error or is disputed, write to [email protected] and we will look into it.

7.5. Invariant: crisis/self-harm content and core safety features (report/block, account deletion) are never tied to money: no donation prompt is shown on those screens.

8. Privacy and Data

8.1. The processing of personal data is described in the Privacy Policy (GDPR). By using the Service, you agree to the processing described there, including the transfer of content to third-party processors for moderation and operation of the Service and international transfers subject to appropriate safeguards.

9. The Operator's Intellectual Property

The name, logo, design, and software of the Service belong to the Operator. These Terms do not transfer any rights in them to you, other than the limited right to use the application for its intended purpose.

10. Disclaimer of Warranties and Limitation of Liability

10.1. The Service is provided "as is" and "as available," without warranties of uninterrupted operation or fitness for a particular purpose, to the extent permitted by law. [Scope of the limitation of liability — for counsel's review; account for the mandatory consumer rights in the EU and other jurisdictions.]

10.2. The Operator is not responsible for third-party user content, but reserves the right to moderate and remove it.

11. Termination

11.1. You may stop using the Service and delete your account at any time (§2.3).

11.2. We may suspend or terminate access in the event of a violation of these Terms, the Community Guidelines, or the law; for serious or repeated violations — without notice (consistent with Apple Guideline 1.2).

12. Changes to the Terms

We may update these Terms. We will notify you of material changes in the app and/or by email; continued use after the changes take effect constitutes acceptance. An archive of versions is available on request.

13. Governing Law and Disputes

These Terms are governed by the law of the Republic of Kazakhstan; disputes shall be heard by the competent court at the Operator's place of business, without prejudice to the mandatory consumer-protection rules and the jurisdiction available to consumers in their country of residence (including the EU). [The final governing-law/jurisdiction clause and any optional pre-litigation or arbitration procedure are subject to counsel's approval.]

14. Contacts

• Support: [email protected] (page)
• DSA contact point (Art. 12) / requests from authorities: [email protected] (Imprint)
• Data inquiries (controller / DPO / EU representative under Art. 27): [email protected] (Privacy Policy)

Appendix A. Compliance Mapping (for internal cross-check)