Company Policy for Online Material Relating to Child Sexual Abuse

July 2022

1. Introduction

In 2016, UNICEF and the GSMA, a global coalition of online companies, developed corporate policies to remove child sexual abuse material online. We support this initiative and are committed to aligning our corporate practices with their guidelines.

In addition, we are committed to supporting the objectives of the Voluntary Principles to Counter Online Child Sexual Exploitation and Abuse. It is a Five Country Ministerial* collaborative initiative, supported by industry-leading technology companies, to combat online child sexual exploitation and abuse.

a. Child sexual abuse material (CSAM), also known as “child sexual abuse content,” refers to material that visually depicts a child engaged in real or simulated explicit sexual activity, or any type of depiction of the sexual parts of a child child for primarily sexual purposes, by any means including photography, video, drawings, cartoons and live streaming.
b. Although the term “child pornography" is frequently used in legislation and international conventions, the term refers to depictions of sexual activity between consenting adults. Therefore, use of the term “child pornography" may mischaracterize sexual performance involving children. For the avoidance of doubt, this Policy refers to “Child Sexual Abuse Material”.
c. Any person under the age of eighteen (18) is defined as a child.

2. General

We are committed to a zero tolerance policy towards material that sexualizes, sexually exploits or endangers children on our platform. If we find or are made aware of such material, we will immediately report it to government authorities.

a. This includes media, text, illustrations or computer-generated images. We consider it our responsibility to ensure that our platform is not used for the distribution or use of CSAM and to discourage users from searching for such content.
b. Any content (real, fictional, or animated) that depicts or depicts children or promotes the sexual exploitation of children is strictly prohibited on our Platform and is a serious violation of our Creator or “Model” Terms of Service.
c. Written content (including, without limitation, comments, content titles, content descriptions, messages, usernames, or profile descriptions) that promotes, refers to, or alludes to the sexual exploitation of children is also strictly prohibited.

3. Report of CSAM

Anyone, whether or not they have an account on our platform, can report violations of these guidelines.

a. If you come across material related to child sexual abuse on Ohlala’s platform, we strongly encourage you to bring it to our attention immediately by reporting the content to us for review. Send us appropriate information via our contact form to report infringing or illegal content. Please include all relevant URL links to the content in question.
b. We report all cases of CSAM to state authorities and the National Center for Missing and Exploited Children (NCMEC), a non-profit organization that provides a central hub for reporting cases of child sexual exploitation online represents. NCMEC makes such reports available to appropriate law enforcement agencies around the world.
c. All complaints and reports to Ohlala will be treated confidentially and will be reviewed by employees who will act responsibly to deal with the content in an appropriate manner.
d. If you believe a child is in imminent danger, we ask that you also immediately notify your local law enforcement authorities.

4. Publication

Do not post any content (visual, audible or written) that depicts, involves or depicts a child or sexualizes a child.

a. This includes content that depicts, involves, or depicts a child (including any illustrated, computer-generated, or other form of realistic depiction of a human child) engaged in sexual behavior or sexually suggestive acts. For a more detailed description, please refer to our Terms of Use for Models.
b. Ohlala reserves the right to determine at any time whether any content is appropriate and consistent with our Model Terms of Service, and Ohlala may, in its sole discretion, remove any Content at any time without notice.
c. Any material related to child sexual abuse brought to our attention will be removed immediately. Users who post abusive content will have their accounts promptly deleted as distributing CSAM is a serious violation of our Terms of Service („Takedown Policy”).

5. Operational Mechanisms

We have operational mechanisms and technological methods in place to counter CSAM.

a. Our team of developers and customer service representatives review content prior to publication to ensure users are not violating our Child Sexual Abuse Material Policy or other policies. If a CSAM is brought to our attention on the Platform, we will remove and review that content and report any material identified as a CSAM.
b. As part of our ongoing efforts, we regularly review our website to ensure our platform remains free of abusive and illegal content.

6. More resources and support

You can contact one of the organizations below to report cases of sexual exploitation or abuse of children. These organizations are committed to abolishing and combating the sexual exploitation of children. Reports can be made anonymously and are an integral part of protecting the safety of children.

International Association of Internet Hotlines
National Center for Missing and Exploited Children (NCMEC)
Internet Watch Foundation

*The Five Country Ministerial is made up of the Departments of Civil Defence, Public Safety and Immigration from Australia, Canada, New Zealand, the UK and the US who have committed to working together on common security challenges.