Child Safety Policy

Last updated: [DATE TO BE SET AT PUBLICATION] Effective from: [DATE TO BE SET AT PUBLICATION]

At TWB (TripsWithBenefits), operated by Little Owl Media S.R.L., we are unequivocally committed to protecting children and preventing any form of child sexual abuse, exploitation, or grooming on our platform.

This policy applies to the entire Service, including:

This policy is published to comply with Apple App Store Review Guidelines (1.2), Google Play Child Safety Standards, the EU Digital Services Act, and applicable national laws including the Romanian Criminal Code provisions on child protection.

1. Zero tolerance

TWB has zero tolerance for child sexual abuse material (CSAM) and any conduct that endangers minors. We strictly prohibit:

  • Any sexual, suggestive, or exploitative content involving anyone under 18, in any form (image, video, text, audio, illustration, AI-generated)
  • Any attempt to contact, befriend, groom, or interact with a minor for any inappropriate purpose
  • Any content that depicts, promotes, normalizes, sexualizes, or trivializes child abuse, exploitation, or trafficking
  • Any speech or behavior that targets minors for harm
  • The creation or use of accounts by anyone under 18
  • The impersonation of a minor or the creation of fictitious minor profiles
  • Soliciting personal information, photos, or any media from a person believed to be a minor
  • Sharing, requesting, or facilitating the sharing of CSAM, whether on or off our platform

Violations result in immediate and permanent account termination and, where required by law, reporting to relevant authorities, including the National Center for Missing & Exploited Children (NCMEC) for incidents involving United States users or content.

2. How we prevent abuse

2.1 Age restriction

The Service is restricted to adults aged 18 and over. Users must confirm their age during signup. We do not knowingly allow anyone under 18 to register.

2.2 Liveness verification

Members may be required to complete a liveness verification process. This process involves submitting two photos performing predefined gestures, which are reviewed by our trained moderation team. We may, at our discretion, require any Member to complete or repeat verification at any time. Among other things, this verification confirms that the person operating the account appears to be an adult.

Profiles that fail verification or appear to be operated by minors are immediately blocked and the account is suspended pending review.

2.3 Manual photo moderation

Every photo uploaded to a public profile is reviewed by a human moderator before becoming visible. Any image suspected of depicting a minor in any context is automatically rejected, the account is suspended pending investigation, and the case is escalated to our safety team.

2.4 In-app reporting

Members can report any suspicious profile, photo, message, or behavior using the "Report" feature available throughout the App. Reports are prioritized as follows:

  • Reports tagged as relating to a minor or child safety: reviewed within 4 hours (24/7)
  • Other safety reports: reviewed within 24 hours

2.5 Automated detection (where applicable)

Where automated tools are used to scan content (such as photo screening services), we configure them to detect CSAM and other harmful content, with all positive matches reviewed by a human before action.

2.6 Blocking

Any Member can block another Member at any time. Once blocked, that Member cannot contact you, view your profile, or interact with you in any way.

2.7 Account termination and prevention of re-registration

Accounts banned for child-safety violations are permanently terminated. Identifiers associated with the banned account are retained to prevent the same individual from creating a new account.

3. How to report a concern

If you witness or experience any behavior that may involve a minor or constitute child sexual abuse, exploitation, or grooming, report it immediately.

3.1 In-app

Use the "Report" feature on the relevant profile, photo, or message. Select the "Child safety" or "Minor involved" category for priority routing.

3.2 By email

Send a detailed report to child-safety@tripswithbenefits.com. Include, if you can do so safely:

  • The Member's display name or any identifying information
  • A description of the concern
  • Screenshots or links (only if you can capture them without participating in or perpetuating harm)
  • The approximate time of the incident

Reports are confidential. We will not disclose the reporter's identity to the reported party.

3.3 Response time and follow-up

We aim to acknowledge child-safety reports within 4 hours and to take protective action (account suspension or removal of content) within 24 hours. Investigations may take longer, but suspensions remain in place pending review.

3.4 In case of imminent danger

If you believe a child is in immediate danger, contact local emergency services first. In Romania: dial 112. In the EU outside Romania: dial 112. In the United States: dial 911. Then report to us via the channels above.

4. Cooperation with authorities

4.1 Reporting obligations

TWB cooperates fully with law enforcement and child-protection authorities worldwide. We comply with valid legal process (court orders, subpoenas, lawful preservation requests) and, where required, voluntarily report incidents involving CSAM to:

  • National Center for Missing & Exploited Children (NCMEC) — United States; CyberTipline at https://report.cybertip.org
  • INHOPE member hotlines — for incidents in EU countries; https://www.inhope.org
  • SaferNet Romania — INHOPE member in Romania; https://www.safernet.ro
  • Directorate for Investigating Organized Crime and Terrorism (DIICOT) — Romania — for serious online child abuse cases
  • Cybercrime Unit, Romanian National Police (Direcția de Combatere a Criminalității Informatice) — www.politiaromana.ro

4.2 Law enforcement requests

We have a dedicated channel for law enforcement requests. Officers may contact: Email: law-enforcement@tripswithbenefits.com

We respond to legally valid requests promptly. Emergency disclosure requests (involving imminent risk of death or serious physical injury) are handled within hours.

4.3 Preservation

Upon receipt of a valid preservation request from law enforcement, we preserve relevant account data, including content slated for deletion, in accordance with applicable law.

5. Resources for victims and families

If you or someone you know has been affected by online child exploitation:

6. Our team's training and resources

Our moderation and safety team:

  • Receives ongoing training on identifying child sexual abuse material, grooming behaviors, and exploitation patterns
  • Has access to industry resources including the NCMEC's Hash-Based Matching tools (where applicable to our scale) and IWF resources
  • Is supported with mental health resources to mitigate the impact of reviewing potentially distressing content

7. Standards we comply with

This Child Safety Policy is designed to meet or exceed:

7.1 Apple App Store

Apple App Store Review Guidelines, Section 1.2 (User-Generated Content), including:

  • A method for filtering objectionable material from being posted
  • A mechanism for users to flag offensive content
  • A mechanism to block abusive users
  • Published contact information for users to easily reach the developer
  • A response within 24 hours to objectionable content concerns

7.2 Google Play

Google Play Developer Program Policies, including the Child Safety Standards (since 2024):

  • Published standards against CSAM and child sexual abuse and exploitation
  • An in-app mechanism for users to report CSAM
  • Mechanism to address reports and remove CSAM
  • Compliance with reporting obligations including those involving NCMEC

7.3 European Union Digital Services Act (DSA)

  • Transparent terms of service
  • Mechanisms for users to report illegal content
  • Cooperation with trusted flaggers
  • Annual transparency reporting (where applicable)

7.4 Romanian law

  • Criminal Code provisions on child pornography (Articles 374-375)
  • Law no. 196/2003 on the prevention and combating of pornography
  • Cooperation with the Romanian National Police and DIICOT

8. Transparency

We publicly commit to:

  • Maintaining and publicizing this Child Safety Policy
  • Reviewing and updating this policy at least annually
  • Training our team on the latest threats and detection methods
  • Cooperating with industry initiatives and information-sharing networks
  • Reporting to NCMEC and other authorities as required by law

If applicable to our scale, we will publish an annual transparency report including:

  • The number of reports received
  • The number of accounts suspended or terminated for child-safety violations
  • The number of reports made to authorities

9. Updates to this policy

We may update this policy as our practices evolve, as we learn from incidents, and as platform and legal requirements change. The date of the last update appears at the top. Material changes will be communicated via email to Members and via in-App notices.

10. Contact

For child-safety matters:

For general inquiries:

Postal mail: Little Owl Media S.R.L. Attn: Trust & Safety Team Str. Nicopole 65, 500063 Brașov, România

11. Language

This Child Safety Policy is made available in multiple languages. The English version is the canonical version and prevails in case of any discrepancy with translations.

Document version: 1.0 Companion documents: Terms of Service · Privacy Policy

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