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 actively work to prevent, detect, and eliminate any such material or behavior.

We comply with all 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 of 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 and Verification

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 implement the following measures to verify age compliance:

• Age declaration during account registration
• Monitoring for indicators of underage users
• Immediate account suspension pending verification when underage use is suspected
• Cooperation with parents/guardians for account removal of underage users

5. Prevention Measures

We employ multiple layers of prevention to protect minors on our platform:

a. Content Filtering

• Automated content filtering systems to detect and block inappropriate content
• Keyword detection for CSAE-related terminology
• Image and video scanning for inappropriate material
• Pattern recognition for grooming behaviors

b. Account Restrictions

• Age-appropriate privacy settings for minor accounts
• Restrictions on adult-minor interactions
• Limited sharing capabilities for new accounts
• Enhanced monitoring of accounts interacting with minors

c. Education and Awareness

• In-app safety resources for parents and minors
• Clear community guidelines visible to all users
• Regular safety reminders and tips
• Partnership with child safety organizations

6. Reporting Mechanisms

7. Response and Investigation Process

When CSAE content or behavior is reported or detected:

1. Immediate Action (Within Minutes):
   • Content is immediately removed from public view
   • Associated accounts are suspended pending investigation
   • Evidence is preserved for law enforcement
2. Investigation (Within 24 Hours):
   • Dedicated safety team reviews the report
   • Additional related content is identified and removed
   • User interaction patterns are analyzed
3. Enforcement:
   • Permanent account termination for violations
   • Device and IP blocking to prevent re-registration
   • Notification to affected users when appropriate
4. Reporting to Authorities:
   • CyberTipline report filed with NCMEC
   • Cooperation with law enforcement investigations
   • Compliance with legal preservation requests

8. Cooperation with Law Enforcement

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

• NCMEC Reporting: We file reports with the National Center for Missing & Exploited Children as required by U.S. law
• Data Preservation: Evidence is preserved for a minimum of 90 days and extended upon 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
• Global Compliance: We work with international law enforcement through appropriate channels

9. Data Handling for CSAE Cases

When handling potential CSAE content or investigations:

• Preservation: All relevant data is immediately preserved in a secure, encrypted format
• Access Control: Only specially trained safety team members can access CSAE-related data
• Retention: Data is retained as required by law (minimum 90 days, extended for active investigations)
• Secure Deletion: After legal retention periods, data is securely and permanently deleted
• Audit Trail: All actions taken on CSAE cases are logged for accountability

10. Appeal Process

Due to the serious nature of CSAE violations:

• Accounts terminated for CSAE violations are permanently banned with no appeal
• False positive reviews are conducted internally but do not delay enforcement action
• 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:

• Regular updates to this policy as threats evolve
• Participation in industry safety initiatives
• Collaboration with child safety organizations
• Regular audits of our safety systems and processes
• Employee training on child safety and CSAE detection

12. Resources for Parents and Guardians

We provide resources to help parents keep their children safe:

• Parental Controls: Information on device-level controls and monitoring
• Safety Education: Guides on talking to children about online safety
• Warning Signs: Information on recognizing grooming and exploitation
• Support Services: Links to counseling and support organizations

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: