Child Safety Standards Policy

App name: Circl – Global Afro Community
Developer: Circl
Last updated: May 23, 2026

1. Our Commitment

Circl is committed to providing a safe environment for all users on our platform. As an 18+ social media application, Circl strictly prohibits minors from creating accounts or accessing the Service. We take child safety extremely seriously and have implemented the standards described below to prevent, detect and respond to any content or behavior that could endanger children.

This policy is published in compliance with the Google Play Child Safety Standards Policy, Apple App Store guidelines, the EU Digital Services Act, and applicable child protection laws including (without limitation) the US PROTECT Act, the EU Child Sexual Abuse Regulation framework, and the French Code pénal (articles 227-23 and following).

2. Definitions

CSAE (Child Sexual Abuse and Exploitation) refers to any content, behavior or activity that sexually exploits, abuses, or endangers children. This includes, but is not limited to:

• Grooming or attempting to groom a child for sexual exploitation;
• Sextortion targeting a child;
• Sex trafficking of a child;
• Producing, distributing, requesting or possessing CSAM;
• Any behavior that places a child at risk of sexual exploitation, harm or endangerment.

CSAM (Child Sexual Abuse Material) refers to any visual depiction — including photos, videos, AI-generated imagery, illustrations, animations or any other visual format — of sexually explicit conduct involving a minor (any person under 18 years of age).

3. Prohibited Conduct

The following are strictly prohibited on Circl and will result in immediate and permanent account termination, reporting to authorities, and where applicable, criminal prosecution:

• Creating, uploading, posting, sharing, distributing, requesting, soliciting, viewing, downloading or storing CSAM in any form;
• Sexualizing, sexually objectifying or making suggestive comments about minors;
• Grooming behavior, including establishing inappropriate contact, building emotional trust, isolating a minor from trusted adults, or sexualized conversations with minors;
• Sextortion or coercing a minor into producing sexual content;
• Sex trafficking, smuggling or facilitation thereof;
• Sharing personal information of minors;
• Creating profiles, characters or AI-generated personas representing minors in any sexual context;
• Linking to, promoting or directing users to external sites containing CSAM;
• Coded language, hashtags, symbols or emojis used to identify, signal or facilitate CSAE;
• Glorifying, normalizing or trivializing CSAE in any form.

4. Age Restriction & Account Eligibility

Circl is strictly limited to users aged 18 years and older. By creating an account, users represent and warrant that they meet this age requirement.

If we become aware that an account belongs to, or is being used by, a person under 18 years of age, that account is immediately suspended and permanently deleted. Any associated content is removed and, where applicable, reported to authorities.

We encourage parents, guardians and any person aware of a minor using Circl to immediately notify us at childsafety@app-circl.com.

5. Detection & Prevention

To enforce these standards, Circl employs the following measures:

• Age declaration at account creation with attestation requirement;
• Content moderation, combining automated detection and human review of reported content;
• Hash-matching technology where applicable, to detect known CSAM through industry databases (such as those maintained by NCMEC, the Internet Watch Foundation, and Project Arachnid);
• In-app reporting mechanism enabling any user to flag suspicious content, profiles or behavior;
• Priority review queue for reports related to child safety, with response objective within 24 hours, in line with the EU Digital Services Act requirements;
• Account restrictions on behaviors that may indicate grooming, including mass messaging to new users.

6. Reporting Mechanisms

In-App Reporting

Users can report any content, profile, message or behavior they consider suspicious or violating this policy directly within the Circl application, using the "Report" function available on each profile, post and message.

Email Reporting

Concerns regarding child safety can also be reported directly to our dedicated Child Safety contact:

External Reporting Resources

If you have witnessed or suspect child exploitation, in addition to reporting to Circl, you may also contact:

• NCMEC CyberTipline (United States): https://report.cybertip.org or +1-800-843-5678;
• INHOPE (international hotline network): https://www.inhope.org;
• Internet Watch Foundation (UK / international): https://www.iwf.org.uk;
• Pharos (France): https://www.internet-signalement.gouv.fr;
• Local law enforcement in your country.

7. Our Response Process

Upon discovering or being notified of CSAE or CSAM content on the Platform, Circl will:

1. Immediately remove the content from the Platform;
2. Permanently terminate all accounts involved, with no possibility of reinstatement;
3. Preserve evidence in compliance with legal requirements (content, metadata, IP addresses, logs);
4. Report to the National Center for Missing & Exploited Children (NCMEC) as required by US federal law (18 U.S.C. § 2258A) for any apparent CSAM;
5. Report to law enforcement in the relevant jurisdictions, including French authorities (Pharos), and cooperate fully with any investigation;
6. Refuse re-registration of users banned for CSAE/CSAM violations.

8. Compliance with Applicable Laws

Circl complies with all applicable child safety laws and regulations, including but not limited to:

• US PROTECT Act and 18 U.S.C. § 2258A (mandatory NCMEC reporting);
• EU Digital Services Act (Regulation 2022/2065);
• EU GDPR (Regulation 2016/679) regarding the processing of minors' data;
• French Code pénal, articles 227-22 through 227-28 (sexual offenses against minors);
• French law no. 2024-449 of 21 May 2024 (SREN) on securing and regulating the digital space;
• UK Online Safety Act 2023;
• Google Play Child Safety Standards Policy;
• Apple App Store Review Guidelines (sections 1.1.4 and 5.1.4).

Circl self-certifies its compliance with these standards through the Google Play Console and the Apple App Store Connect submission process.

9. Training & Internal Procedures

All Circl team members involved in moderation, content review, user support or any role that may encounter CSAE/CSAM are trained on:

• Identifying CSAE and CSAM in all its forms;
• Mandatory reporting procedures;
• Evidence preservation requirements;
• Confidentiality obligations toward victims;
• Psychological support resources for moderators exposed to such content.

Circl follows the best practices recommended by the Tech Coalition for combating online child sexual exploitation and abuse.

10. Cooperation with Authorities & Industry

Circl cooperates fully with law enforcement, judicial authorities, regulators and recognized child protection organizations. We respond to lawful requests for information, preservation orders and removal demands in accordance with applicable laws.

We also participate, where possible, in industry-wide efforts to combat CSAE, including collaboration with NCMEC, INHOPE, the Internet Watch Foundation, and the Tech Coalition.

11. Annual Review

This Child Safety Standards Policy is reviewed at least annually, and updated whenever required by changes in applicable laws, platform policies, or industry best practices.

12. Contact

For all child safety-related matters, including reports, inquiries from Google Play, Apple App Store, regulators or law enforcement, please contact:

This contact is authorized to address Circl's child safety enforcement and review procedures, and to take immediate action upon receiving credible notifications.

13. Related Policies

This Child Safety Standards Policy is part of Circl's broader user agreement. Please also review:

• Terms of Use – our general contractual agreement;
• Community Guidelines – detailed rules of conduct for all users;
• DMCA Policy – copyright protection procedures;
• Privacy Policy – how we handle personal data.