This Child Safety Standards policy applies to all services and applications operated or provided by SMK (hereinafter referred to as the “Company”).
The Company is committed to protecting children and minors and maintaining a safe environment for all users. The Company applies a zero-tolerance approach to child sexual abuse and exploitation (CSAE), child sexual abuse material (CSAM), grooming, sexual exploitation, and other conduct that may place children or minors at risk.
The Company seeks to comply with applicable child-safety, privacy, data-protection, and online-platform laws in the jurisdictions in which its services and applications are available, including applicable requirements of the European Union and European Economic Area (EU/EEA).
The Company strictly prohibits any form of child sexual abuse or exploitation, including but not limited to:
Violations may result in immediate removal or restriction of content, account suspension, permanent account termination, restriction of access to services or applications, and other appropriate measures.
Where required or permitted by applicable law, suspected illegal activity may be reported to law enforcement agencies, child-protection authorities, or other competent organizations.
The Company's services and applications are intended for users who satisfy the minimum age requirement specified for the applicable service and jurisdiction. Unless otherwise expressly stated for a particular service, the Company's services and applications are intended for users aged 18 or older.
The Company does not knowingly permit children or minors to access services that are restricted to adults.
If the Company becomes aware or reasonably suspects that an account violates an applicable age requirement, the Company may suspend, restrict, or permanently remove the account, subject to applicable law.
Where a service is intended for or accessible by children or minors, the Company will implement appropriate safeguards required by applicable law, including requirements concerning age assurance, parental consent where legally required, protection of children's personal data, and the safety of minors.
For EU/EEA users, the Company takes into account applicable requirements concerning the protection of minors under the Digital Services Act (DSA), the General Data Protection Regulation (GDPR), and other applicable European or national laws.
The Company provides reporting or inquiry mechanisms through applicable services and applications to allow users to report suspected illegal content, CSAE, CSAM, grooming, sexual exploitation, or other serious child-safety concerns.
Users should report content or conduct that they reasonably believe to be illegal or that presents a serious risk to children or other users.
A report does not require the reporter to make a final legal determination. The Company will assess reported information based on the facts and circumstances available to it and applicable law.
Where the Digital Services Act applies to the Company's service, the Company will maintain an appropriate notice-and-action mechanism for reporting illegal content and will process qualifying notices in accordance with applicable DSA requirements.
When the Company receives a child-safety or illegal-content report, it may take the following measures depending on the circumstances:
Reports will be handled as promptly as reasonably practicable, taking into account the seriousness and urgency of the reported matter, applicable law, available information, and the need to protect users and preserve evidence.
The designated Administrator receives child-safety reports and coordinates the review and appropriate handling of reports involving children or minors.
The Child Safety Point of Contact may coordinate with relevant internal personnel and, where appropriate or legally required, cooperate with law enforcement agencies, child-protection authorities, regulatory authorities, or other competent organizations.
Users may contact the Child Safety Point of Contact directly using the email address above or use the reporting mechanisms available within the applicable service or application.
For services to which the Digital Services Act (DSA) applies, users in the EU/EEA may report content they reasonably believe to be illegal under EU law or the law of an EU Member State through the Company's applicable reporting mechanism.
The Company will provide an appropriate mechanism for submitting sufficiently precise and adequately substantiated notices where required by the DSA.
Where a report qualifies as a notice of illegal content under applicable DSA requirements, the Company will process the notice in accordance with the applicable legal requirements and will communicate the outcome of the report as required.
Where content or an account is restricted or removed, the Company will provide an appropriate statement of reasons where required by applicable law.
Where applicable, users may challenge certain content-moderation decisions through the Company's internal complaint-handling mechanism. Users may also have rights to seek independent out-of-court dispute settlement or judicial remedies under applicable law.
The DSA provides users with mechanisms to report illegal content and, where applicable, challenge content-moderation decisions through internal complaint procedures or certified out-of-court dispute settlement bodies.
The Company takes reasonable and proportionate measures to protect minors from risks associated with its services and applications, taking into account the nature, functionality, and intended audience of each service.
Where applicable, these measures may include age-related restrictions, reporting and blocking mechanisms, moderation measures, safety information, and other technical or organizational safeguards.
The Company will not knowingly use child-safety measures in a manner that unnecessarily exposes children or minors to additional risks.
Where the Company provides services accessible to minors, the Company will take into account applicable European requirements concerning the protection of minors online and applicable data-protection principles.
Personal data submitted through child-safety or illegal-content reports will be processed in accordance with applicable data-protection laws, including the GDPR where applicable.
The Company will process personal data contained in reports only to the extent reasonably necessary for purposes such as:
The Company will apply appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction.
The identity and personal information of reporters will be protected to the extent reasonably possible. Information will not be unnecessarily disclosed except where disclosure is required or permitted by applicable law.
Where the GDPR applies, users may have rights including the right to access, rectification, erasure, restriction of processing, data portability, and objection, subject to the conditions and exceptions provided by law.
Users may exercise applicable data-protection rights by contacting the Company through the contact information provided in the Company's Privacy Policy.
The Company will generally respond to valid GDPR rights requests without undue delay and, in principle, within one month, subject to applicable legal extensions or exceptions.
Where a request cannot be fulfilled, the Company will provide an explanation where required by law and inform the user of applicable rights to lodge a complaint with a competent supervisory authority.
The Company will take reasonable measures to protect individuals who submit child-safety or illegal-content reports from unnecessary disclosure or retaliation.
Reports may contain sensitive information. Reporters should provide only information reasonably necessary to allow the Company or competent authorities to assess the reported matter.
Reporters should avoid unnecessarily submitting personal information belonging to themselves, children, victims, or other individuals unless it is relevant to the report.
The Company's reporting mechanisms are not intended to replace emergency services.
If a child or minor is in immediate danger, users should contact the appropriate local emergency service or law enforcement authority immediately and should not wait for the Company's internal reporting process.
The Company may cooperate with competent authorities and provide information where legally required or where otherwise permitted by applicable law.
Users may report suspected child sexual abuse, exploitation, CSAM, grooming, or other serious child-safety concerns directly to competent authorities or recognized reporting organizations in their jurisdiction.
EU/EEA users may contact their relevant national law-enforcement or child-protection authority. Users may also contact the Digital Services Coordinator in their EU Member State for matters concerning applicable DSA obligations.
Users in the United States may report suspected child sexual exploitation to the National Center for Missing & Exploited Children (NCMEC) through its official reporting channels.
Users in other jurisdictions should contact the appropriate national or regional child-protection or law-enforcement authority.
Depending on the circumstances and applicable law, violations of these standards may result in:
The Company may take immediate protective measures without prior notice where necessary to protect children, prevent further harm, preserve evidence, or comply with applicable law.
Where required by applicable law, including the DSA where applicable, the Company will provide users with an appropriate explanation of material content-moderation or account-enforcement decisions.
Such explanations may identify the relevant rule or legal basis and provide information about available complaint or appeal mechanisms, subject to legal restrictions, security considerations, and the protection of confidential information.
The Company may cooperate with law enforcement agencies, child-protection authorities, Digital Services Coordinators, data-protection authorities, courts, and other competent authorities when required or permitted by applicable law.
The Company may preserve or disclose relevant information in response to valid legal requests or where necessary to comply with legal obligations, protect children or users, prevent serious harm, or establish, exercise, or defend legal claims.
The Company may update these Child Safety Standards to reflect changes in applicable laws, regulations, platform requirements, or operational practices.
Any updated version will be published on the official policy page and will become effective as specified in the updated policy.
Effective Date: February 12, 2024