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Child Sexual Abuse Material (CSAM) and Illicit Content Policy

Child Sexual Abuse Material (CSAM) and Illicit Content Policy

Last updated October 30, 2024
Effective October 30, 2024

We are deeply committed to maintaining a safe, legal, and respectful environment for all users on our platform. As part of this commitment, we strictly prohibit the creation, distribution, or facilitation of Child Sexual Abuse Material (CSAM) and all other forms of exploitative content involving minors. Our policies are designed in alignment with federal laws, including 18 U.S.C. § 2252, and reflect our responsibilities as a registered Electronic Service Provider (ESP) with the National Center for Missing and Exploited Children (NCMEC) and our compliance with the REPORT Act. This policy outlines our approach to prohibited content, reporting obligations, user responsibilities, and enforcement actions.

Technology and Monitoring

To uphold this policy, we use industry-standard technologies and procedures, including but not limited to:

  • Automated Scanning Tools: Our platform employs sophisticated technology to detect and flag potentially illegal content, including imagery, text, and behavioral patterns that suggest grooming or other exploitative actions.
  • Behavioral Pattern Recognition: We utilize AI-based monitoring tools to identify patterns consistent with grooming and solicitation, which are promptly reviewed by our safety team.

Review Process

Content flagged by our automated tools is escalated for immediate human review to ensure compliance with our zero-tolerance approach. Our team assesses flagged content to confirm if it meets the criteria for prohibited CSAM or grooming activities.

Obligatory Reporting to NCMEC and Law Enforcement

In accordance with our legal obligations under the REPORT Act and our partnership with NCMEC:

  • We immediately report verified CSAM and instances of grooming or solicitation to NCMEC’s CyberTipline.
  • Detailed information concerning the incident is provided, including any identifiable information about the content’s source, such as user ID, IP address, and activity logs as permitted by law.
  • We follow NCMEC’s reporting guidelines to support investigations and contribute to the swift identification and rescue of exploited children.

Compliance with the REPORT Act

Our responsibilities under the REPORT Act include:

  • Mandatory Reporting: All ESPs, including our platform, are legally required to report any discovered CSAM or exploitation-related content. Our reports are submitted promptly and with all relevant details, in strict compliance with the Act.
  • Comprehensive Documentation: We maintain records of all reports, including CSAM, grooming, and other related incidents, to meet regulatory standards and ensure our compliance efforts are transparent and effective.
  • Continuous Updates: Our procedures and technologies are regularly updated to align with any changes or new guidance under the REPORT Act, NCMEC guidelines, and federal law.

3. Content Review, Removal, and Enforcement Actions

Zero-Tolerance Policy for Prohibited Content

We maintain a strict zero-tolerance policy for CSAM, grooming, and any other exploitative or illegal content involving minors. Our actions include:

  • Immediate Removal: Verified instances of CSAM or related content are removed from the platform without delay.
  • Account Suspension or Termination: Users involved in the distribution, creation, or solicitation of CSAM or related content are subject to account suspension or termination. Any account found to be involved in online grooming, solicitation of minors, or attempts to normalize inappropriate conduct will also be immediately suspended.
  • Non-Refundability: Accounts terminated for violating this policy are not eligible for any refunds or reimbursement of fees paid for services, features, or subscriptions. This non-refund clause applies in all cases where prohibited content violates our Terms of Service, which state that users must adhere to all applicable laws and our platform’s safety policies.

4. User Responsibilities and Reporting Violations

Users are expected to adhere to both the Terms of Service and the legal requirements associated with our platform, particularly regarding child protection. Engaging in, attempting, or facilitating illegal activities involving minors is strictly prohibited.

How to Report Violations

If users encounter any suspected CSAM, grooming behaviors, or exploitative content on our platform, they are encouraged to report it immediately:

  • Contact Channels: Reports can be made via our reporting tool on the platform (coming soon) or by contacting us at csam-compliance@tcf.ventures.

    Please do not submit CSAM reports through the service desk, doing so may cause a delay in processing.
  • Anonymity and Safety: Reports can be submitted anonymously to protect the user’s identity while ensuring the issue is addressed promptly. Unless required by court order, identities will not be decrypted or disclosed from any reports made in good faith, including anonymous and non-anonymous reports.

All reports are reviewed and assessed by our safety team to determine the nature of the content and initiate appropriate actions. We maintain strict protocols to ensure user safety, and retaliation against reporting users is prohibited.

5. Privacy and Confidentiality in Reporting

We understand the importance of user privacy and confidentiality, especially in sensitive situations. All reports of CSAM and grooming are handled with the highest degree of confidentiality. Our approach to privacy in the context of reporting is as follows:

  • Secure Handling: Information related to CSAM reporting is stored and managed using industry-standard security protocols, protecting both the identity of the reporting user and the investigation’s integrity.
  • Restricted Disclosure: User information related to CSAM or grooming incidents is only shared with authorized parties, including NCMEC and law enforcement, as required by law.
  • Data Retention: Information and data collected as part of CSAM reporting are retained only as long as necessary to comply with legal and regulatory obligations.

6. Policy Updates

We may update this policy to reflect changes in the law, best practices, or enhancements to our safety measures. All updates will be posted here, and we encourage users to review this policy periodically to stay informed about our commitment to compliance, user safety, and responsible platform management.

Continued use of our platform after updates to this policy constitutes acceptance of any new terms.