1. Purpose & Commitment

We are committed to providing a safe environment and to preventing any form of child sexual abuse or exploitation on or through our app. We enforce a zero-tolerance policy toward any content, behavior, or user that engages in, promotes, facilitates, or tolerates child sexual abuse, exploitation, or grooming.

2. Scope

This policy applies to:
• All users of the app (regardless of age)
• All content submitted, shared, or exchanged (images, videos, text, audio, links)
• All communications, messages, and interactions occurring via the app
• All user profiles, metadata, and any user-generated content

3. Definitions
• Child / Minor: Any person under the age of 18 (or the applicable age threshold under local law).
• CSAE (Child Sexual Abuse & Exploitation): Any behavior that involves a child in sexual activities, regardless of consent; this includes grooming, sexual extortion, facilitating or promoting exploitation, etc.
• CSAM (Child Sexual Abuse Material): Any content that visually depicts a child in sexual activities or for sexual purposes.
• Grooming: Acts done to befriend or establish an emotional connection with a minor, with the purpose of manipulating or exploiting them sexually.

4. Prohibited Conduct

Under no circumstances will the following be permitted:
• Uploading, distributing, soliciting, or sharing CSAM
• Sexualizing minors in any content (including imagery, text, roleplay, fantasies)
• Encouraging or facilitating any sexual activity involving a minor
• Grooming minors (e.g. attempts to gain trust, misrepresenting age, flattery, exchanging sexual content with the aim to exploit)
• Sextortion (threatening to release content unless sexual acts are performed)
• Any links, references, or pointers to repositories or sites hosting child sexual materials
• Any discussion or instructions about how to access or produce CSAM

5. Detection, Reporting & Enforcement

5.1 Detection
• We will use a combination of manual review, automated tools (image hashing, content filters), and user reports to identify potential CSAE content.
• When possible, content suspected of being CSAM will be blocked, removed, and escalated for review.
• We may suspend or restrict accounts showing suspicious behavior, pending review.

5.2 Reporting
• Upon detection of CSAE / CSAM, we will immediately remove or disable access to the content, subject to legal obligations.
• We will report the incident to relevant law enforcement or child protection authorities, in accordance with applicable local and international laws.
• Where required, we will cooperate with law enforcement in investigations.

5.3 Enforcement
• Users found to violate this policy will face immediate suspension or termination of account, without prior warning.
• Any content or accounts associated with CSAE or CSAM may be permanently banned or blacklisted.
• We reserve the right to refuse re-registration by banned users.
• We may take additional actions (e.g. legal action) depending on severity.

6. Feedback & User Reporting Channel
• We will provide an in-app reporting mechanism for users to report suspected abuse, exploitation, or policy violations.
• Reports may be submitted anonymously, but we encourage users to provide contact information to facilitate follow-up.
• We commit to reviewing reports in a timely manner (e.g. within 24–48 hours) and responding or acting accordingly.

7. Child Safety Point of Contact

We will designate a Child Safety Officer / or Safety Contact (a person or role, e.g. “Safety & Compliance Lead”) whose contact information is publicly available. This contact is responsible for handling CSAE reports, coordinating with authorities, and compliance.

Child Safety Contact
Email: legal@uniout.gr

8. Legal Compliance & Cooperation
• We comply with all applicable national and international laws related to child protection and reporting of CSAM / CSAE.
• We will cooperate with law enforcement and regulators, while respecting user privacy and due process.
• If local law requires preservation of data, we shall follow those rules (e.g. retention of logs) consistent with legal constraints.

9. Privacy, Data Handling & Confidentiality
• When processing reports or investigations, user privacy should be respected to the maximum extent possible.
• Sensitive data may be shared only with authorized personnel or law enforcement, under appropriate safeguards.
• We will maintain appropriate security, access controls, and internal policies to protect personal data.

10. Training & Awareness
• Even though you don’t have a dedicated team or AI currently, you may consider (over time) training moderators, support staff, or contractors to recognize and respond to potential CSAE content.
• Incorporate awareness in your developer / staff guidelines.

11. Review, Updates & Transparency
• This policy should be reviewed and updated periodically (e.g. annually or when laws change).
• Significant updates should be published and versioned.
• We may (optionally) publish transparency reports summarizing CSAE incidents, report statistics, enforcement actions.

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