Child Safety and CSAE Policy

1. Our Commitment to Child Safety

At Closerr, the safety and wellbeing of all users, particularly minors, is our highest priority. We are committed to maintaining a platform free from child sexual abuse and exploitation (CSAE) content and to acting quickly on any such material or behavior we become aware of.

We comply with applicable laws and regulations regarding child safety, including but not limited to:

• The Children's Online Privacy Protection Act (COPPA)
• 18 U.S.C. §2258A — reporting requirements for providers
• International child protection laws where we operate
• Google Play Store and Apple App Store policies on child safety

2. Definition of Prohibited CSAE Content

To be clear: Normal family photos and parenting content are NOT considered CSAE content. Parents sharing their children's milestones, achievements, and everyday moments is a core use case for Closerr.

The following content is strictly prohibited on Closerr and will result in immediate account termination:

• Child Sexual Abuse Material (CSAM): Any visual depiction of sexually explicit conduct involving minors
• Sexualization of Minors: Content that sexualizes or promotes the sexual exploitation of minors
• Grooming: Any attempt to build a relationship with a minor for the purpose of sexual exploitation
• Sexual Solicitation: Requesting, demanding, or soliciting sexual content from minors
• Trafficking: Content that promotes, facilitates, or participates in child trafficking
• Inappropriate Interactions: Adults engaging in sexually suggestive conversations with minors
• Sharing Personal Information: Distributing private information about minors that could lead to exploitation

3. Legitimate Family Content Guidelines

Closerr is designed to help families stay connected. We actively encourage parents and guardians to share appropriate content about their children with trusted family and friends.

Examples of Welcome Content

• Photos from family gatherings, birthdays, and holidays
• Updates about school achievements and milestones
• Videos of sports events, recitals, and performances
• Everyday moments that capture childhood memories
• Family vacation photos and adventures
• Baby photos and developmental milestones

Best Practices for Sharing Family Content

• Consider your child's privacy and future digital footprint
• Avoid sharing embarrassing or potentially harmful content
• Be mindful of including other people's children in photos
• Use privacy settings to control who can see family content
• Respect your child's wishes as they grow older

4. Age Requirements

Minimum Age: Users must be at least 13 years old to create an account on Closerr. In jurisdictions where the minimum age is higher, users must meet that requirement.

We do not currently verify age at signup. If we become aware — including through a user report — that an account belongs to someone under our minimum age, we will act on it, up to and including account removal, and will cooperate with a parent or guardian requesting that removal.

5. Prevention Measures

a. Content Filtering

We run automated text-based filtering on posts and comments to detect and block prohibited language and content patterns at the point of posting. This is a text-content check, not automated scanning of images, video, or audio, and it is not a grooming-detection system — it works alongside, not instead of, human review of user reports.

b. Reporting and Blocking

• Any user can report a post, comment, chat message, or profile directly in the app
• Blocking a user removes their content from your feed and chat immediately, without needing to refresh
• Reports are reviewed by our team through an internal moderation dashboard

c. Community Guidelines

Our Terms of Service set out prohibited content and conduct, and are available to every user before they create an account.

6. Reporting Mechanisms

7. Response and Investigation Process

When CSAE content or behavior is reported or detected:

1. Content and Account Action:
   • Reported content is removed from public view once reviewed
   • Accounts found in violation are terminated
   • A snapshot of the reported content is preserved as evidence at the time of the report
2. Review:
   • Our team reviews the report and any directly related content
3. Enforcement:
   • Permanent account termination for confirmed violations
   • Notification to affected users when appropriate
4. Reporting to Authorities:
   • CyberTipline report filed with NCMEC as required by law
   • Cooperation with law enforcement investigations
   • Compliance with legal preservation requests

We don't currently publish a guaranteed response time for reports. Emergency situations should always go to local law enforcement directly, not to us.

8. Cooperation with Law Enforcement

Closerr maintains a zero-tolerance policy and cooperates with law enforcement agencies:

• NCMEC Reporting: We file reports with the National Center for Missing & Exploited Children as required by U.S. law
• Data Preservation: When a report is made against a user's account, that report and its evidence snapshot are retained for a minimum of 90 days even if the reported user deletes their account, and longer upon a valid legal request
• Legal Process: We respond to valid subpoenas, court orders, and search warrants
• Proactive Cooperation: We voluntarily share information when children are at risk

9. Data Handling for CSAE Cases

When handling potential CSAE content or investigations:

• Preservation: A snapshot of reported content is preserved at the time of the report, independent of later account or content deletion
• Retention: Retained for a minimum of 90 days, and longer for active investigations or legal holds
• Secure Deletion: After the retention period, and absent an active legal hold, retained report data is permanently deleted

10. Appeal Process

Due to the serious nature of CSAE violations:

• Accounts terminated for CSAE violations are permanently banned with no appeal
• Users falsely accused can provide evidence to safety@closerr.app for review
• Deliberate false reporting of CSAE content is itself a violation resulting in account termination

11. Transparency and Accountability

We are committed to transparency in our child safety efforts:

• This policy is updated as our practices, or the law, change
• Enforcement actions we take (content removal, account termination) are logged internally

12. Resources for Parents and Guardians

We don't run our own parental-safety content library. These established external resources are a good starting point:

• NCMEC: missingkids.org — safety guides and the CyberTipline
• Common Sense Media: commonsensemedia.org — age-appropriate technology guidance
• Your device's built-in parental controls — iOS Screen Time or Android Family Link, for account-level and time-based supervision

13. Policy Updates

This policy may be updated periodically to reflect changes in law, technology, or our practices. Significant changes will be communicated to users through in-app notifications or email. The "Effective Date" at the top of this policy indicates when it was last revised.

14. Contact Us

For questions about this Child Safety and CSAE Policy or to report concerns: