Child Safety Standards

1 Introduction and Scope

BakkMe is a social platform that provides social media, fundraising, payments, live streaming, groups, chat, and creator monetization features. We are deeply committed to the safety and protection of all users, with a particular focus on safeguarding children and young people from harm.

This Child Safety Standards document outlines our comprehensive policies, procedures, and technical measures designed to prevent, detect, and respond to child sexual abuse and exploitation (CSAE), grooming, and other risks to minors on our platform.

1.1 Scope of This Policy

This policy applies to:

• All users of the BakkMe platform, including the mobile application (com.bakkme.app (Android) / com.bakkme.io (iOS)), web application, and any associated services.
• All forms of content shared on the platform, including text, images, videos, audio, live streams, messages, group content, fundraiser descriptions, and profile information.
• All features of the platform, including but not limited to social feeds, groups, direct and group messaging, live streaming, payments, fundraising campaigns, and creator monetization tools.
• All BakkMe employees, contractors, moderators, and third-party partners who have access to user content or platform systems.

1.2 Legal Framework

This policy has been developed in compliance with and informed by the following laws and regulations:

• United States: Children's Online Privacy Protection Act (COPPA), PROTECT Act, EARN IT Act, STOP CSAM Act, and applicable state laws.
• European Union: General Data Protection Regulation (GDPR), Digital Services Act (DSA), and the proposed Child Sexual Abuse Regulation.
• United Kingdom: Online Safety Act 2023, Age Appropriate Design Code (Children's Code), Sexual Offences Act 2003, and the UK GDPR.
• International: United Nations Convention on the Rights of the Child (UNCRC), WePROTECT Global Alliance Model National Response, and the Voluntary Principles to Counter Online Child Sexual Exploitation and Abuse.
• Platform Policies: Google Play Families Policy and Child Safety Standards, Apple App Store Review Guidelines (Section 1.2 — Safety — Kids Category).

1.3 Our Commitment

BakkMe commits to implementing and continuously improving industry-leading child safety measures. We work collaboratively with law enforcement, child safety organizations, industry peers, and policy experts to ensure the highest standards of protection for children on our platform.

2 Age Requirements

BakkMe enforces strict age requirements to protect children and ensure that features are appropriate for each user's age group.

2.1 Minimum Age Requirement

2.2 Age-Restricted Features

Certain features on BakkMe require users to be 18 years of age or older:

2.3 Age Verification and Enforcement

• Date of birth collection: All users must provide their date of birth during account registration. This information is used to determine eligibility and apply appropriate safety features.
• Age gate enforcement: Users who do not meet the minimum age requirement are prevented from creating an account. We do not retain personal data of users who fail age verification.
• Ongoing verification: BakkMe uses signals-based age estimation and may require additional age verification (such as identity document verification) for access to age-restricted features, particularly payments, fundraising, and live streaming.
• False age detection: We employ technical systems and behavioral analysis to detect users who may have misrepresented their age. If a user is determined to be underage, their account will be suspended and age-restricted features will be disabled.
• Parental consent: In jurisdictions requiring parental or guardian consent for users between 13 and the local age of digital consent, BakkMe implements verifiable parental consent mechanisms in compliance with applicable law.

3 Zero-Tolerance for Child Sexual Abuse and Exploitation (CSAE)

3.1 Prohibited Content and Conduct

The following is strictly prohibited on BakkMe without exception:

3.1.1 Child Sexual Abuse Material (CSAM)

• Any visual depiction (photographs, videos, or digitally-generated imagery) of a minor engaged in sexually explicit conduct.
• Any visual depiction that has been created, adapted, or modified to appear as though a minor is engaged in sexually explicit conduct.
• Content that depicts, promotes, or normalizes the sexual abuse of children, including drawn, animated, or cartoon representations.
• Links to or solicitation for CSAM, including on external platforms or services.

3.1.2 AI-Generated and Synthetic CSAE Content

• AI-generated, deepfake, or synthetically created sexual imagery of minors, regardless of whether a real child was involved in its production.
• Use of AI tools or generative models to create, modify, or enhance imagery to sexualize minors.
• Digitally altered images of real children placed into sexual contexts.
• Text-based AI-generated descriptions of child sexual abuse.

3.1.3 Grooming and Predatory Behavior

• Initiating or attempting to initiate sexual contact or communication with a minor.
• Building a relationship with a minor for the purpose of sexual exploitation, whether on-platform or off-platform.
• Manipulating a minor into producing sexual content or engaging in sexual activities.
• Sending unsolicited sexually explicit content to minors.
• Requesting personal information, private photos, or videos from minors for exploitative purposes.
• Offering gifts, money, or other inducements (including through BakkMe payment features) to minors in exchange for sexual content or contact.
• Attempting to move conversations with minors to less monitored platforms or private channels.

3.1.4 Exploitation and Trafficking

• Sex trafficking of minors or any content facilitating child trafficking.
• Commercial sexual exploitation of children (CSEC), including child sex tourism.
• Using BakkMe features (fundraising, payments, groups) to facilitate the exploitation of children.
• Advertising or soliciting minors for sexual purposes.

3.1.5 Other Prohibited Content

• Content that sexualizes minors in any way, including inappropriate comments on content featuring minors.
• Content that promotes or glorifies child abuse, including physical and emotional abuse.
• Content that identifies or could lead to the identification of child victims of sexual abuse.
• Sharing non-sexual images of children with sexually suggestive captions or commentary.
• Fetishization of minors or content involving minors in contexts with underlying sexual themes.
• Collections of non-sexual images of children compiled for the purpose of sexual gratification.

3.2 How We Detect CSAE Content

BakkMe deploys multiple layers of technology and human review to detect and prevent CSAE content:

• Hash-matching technology: We use PhotoDNA and other perceptual hash-matching technologies in collaboration with NCMEC to detect known CSAM before it is distributed on our platform.
• AI-powered classifiers: Machine learning models trained to detect previously unknown CSAE content, including AI-generated/synthetic imagery, grooming patterns in text, and age estimation in visual content.
• Behavioral analysis: Automated systems that identify patterns consistent with grooming behavior, predatory networking, and exploitation.
• Proactive scanning: All uploaded images and videos are scanned against known CSAM databases before being made available to other users.
• Keyword and pattern detection: Natural language processing systems identify coded language and known terminology associated with CSAE.

4 Content Moderation

BakkMe operates a multi-layered content moderation system specifically designed to prioritize child safety across all platform features.

4.1 Automated Detection Systems

• Pre-publication scanning: All images, videos, and live stream content are scanned using hash-matching (PhotoDNA) and AI-based classifiers before being shared or broadcast on the platform.
• Real-time monitoring: Live streams are subject to continuous automated monitoring using computer vision and audio analysis to detect inappropriate content involving minors.
• Text analysis: Messages, comments, captions, group posts, and fundraiser descriptions are analyzed using natural language processing to detect grooming patterns, CSAE-related language, and solicitation of minors.
• Behavioral signals: Our systems monitor user behavior patterns, including messaging frequency with minors, friend request patterns, and age-gap interactions, to identify potential predatory activity.
• Link detection: URLs shared on the platform are scanned against databases of known CSAM distribution sites and flagged for review.

4.2 Human Review Team

• Dedicated child safety team: BakkMe maintains a specialized team of trained child safety specialists who review flagged content, conduct investigations, and make enforcement decisions.
• 24/7 coverage: Our child safety moderation team operates around the clock to ensure rapid response to reports and flagged content.
• Specialized training: All child safety reviewers undergo extensive training on CSAE identification, trauma-informed practices, legal obligations, and reporting protocols. Training is refreshed at minimum every six months.
• Psychological support: BakkMe provides mandatory psychological support, including access to counselors, wellness programs, and regular debriefings for moderation staff exposed to harmful content.

4.3 Priority Review for Child Safety

• Child safety reports are automatically escalated above all other content moderation queues.
• Reports involving imminent danger to a child trigger emergency protocols, including immediate content removal and, where warranted, direct contact with law enforcement.
• Automated detections of CSAM result in immediate content removal and account suspension, pending human review and NCMEC reporting.

5 Reporting Mechanisms

BakkMe provides multiple accessible channels for reporting child safety concerns. We encourage all users, parents, guardians, and external parties to report any content or behavior that may endanger children.

5.1 In-App Reporting Tools

• Content reporting: Every piece of content on BakkMe (posts, images, videos, comments, messages, live streams, fundraisers, group posts) includes a visible report button. When reporting, users can select "Child Safety" or "Child Exploitation" as the report reason.
• Profile reporting: Users can report an entire profile if they believe a user poses a risk to children. A dedicated "Report for Child Safety" option is available on all profiles.
• Live stream reporting: During any live stream, viewers have immediate access to a prominently displayed report function with a specific option for child safety concerns.
• Chat reporting: Individual messages and entire chat conversations can be reported for child safety concerns directly from the messaging interface.
• Anonymous reporting: Users may submit child safety reports without their identity being disclosed to the reported user.

5.2 Email Reporting

5.3 External Reporting

In addition to reporting to BakkMe, we strongly encourage reporting to the appropriate authorities:

5.4 Reporter Protections

• BakkMe does not retaliate against users who make good-faith reports of child safety concerns.
• Reporter identities are kept confidential and are not shared with the reported party.
• Users who report child safety concerns will receive an acknowledgment and, where possible and appropriate, updates on actions taken.

6 Enforcement Actions

BakkMe takes swift and decisive action against any user who violates our child safety policies. Enforcement actions are proportionate to the severity of the violation and prioritize the safety of children above all other considerations.

6.1 Immediate Content Removal

• Any content identified as CSAM, exploitative, or otherwise harmful to children is removed immediately upon detection or verification.
• Content is removed before any investigation is completed if there is reasonable suspicion that it involves CSAE.
• Removed CSAE content is not recoverable by the violating user under any circumstances.

6.2 Account Suspension and Termination

6.3 Law Enforcement Referral

• BakkMe reports all confirmed and suspected instances of CSAM to the National Center for Missing & Exploited Children (NCMEC) via the CyberTipline, as required by US federal law (18 U.S.C. § 2258A).
• We cooperate fully and promptly with law enforcement investigations related to child exploitation, providing requested information in accordance with valid legal process.
• In cases involving imminent danger to a child, BakkMe may proactively contact local law enforcement without waiting for a formal legal request.
• BakkMe collaborates with international law enforcement agencies, including Interpol, Europol, and national child exploitation units.

6.4 Evidence Preservation

• When CSAE content or behavior is identified, BakkMe preserves all relevant evidence, including the content itself, associated metadata, account information, IP addresses, device identifiers, timestamps, and communication logs.
• Evidence is preserved securely and in a forensically sound manner to support potential criminal investigations and prosecutions.
• Preserved data is stored in a restricted-access environment with strict access controls, accessible only to authorized child safety and legal personnel.
• Evidence is retained for the period required by applicable law and in cooperation with law enforcement directives.
• BakkMe does not notify users who are the subject of a CSAE investigation that their data has been preserved or reported, so as not to interfere with potential investigations.

6.5 Ban Evasion Prevention

• Users permanently banned for CSAE violations are prohibited from creating new accounts on BakkMe.
• We use device fingerprinting, email analysis, IP tracking, and behavioral signals to detect and prevent ban evasion attempts.
• Accounts identified as ban evasion attempts by CSAE offenders are immediately terminated.

7 Safety Features for Young Users

BakkMe implements additional protective features for users under 18 to reduce their exposure to potential risks while still enabling a positive platform experience.

7.1 Private Accounts by Default

• All accounts belonging to users under 18 are set to private by default.
• Private accounts require the user to approve follow requests before anyone can view their content or activity.
• Minors are informed about the importance of maintaining a private account and receive prompts if they attempt to change their account to public.

7.2 Limited Discoverability

• Accounts of users under 18 are excluded from public search results, recommendations to non-connected users, and explore/discovery features visible to adults.
• Content posted by minors is not surfaced in algorithmic recommendations to adult users who do not already follow the minor.
• Minors' profiles do not appear in "suggested users" lists for adult accounts.

7.3 Restricted Contact and Messaging

• Adult users who are not mutual followers of a minor cannot send direct messages to that minor.
• Group invitations to minors from adults who are not mutual connections are restricted.
• When a minor receives a message from an adult they do not follow, the message is filtered and the minor is shown a safety prompt before they can view it.
• Message requests from flagged or suspicious accounts to minors are automatically blocked.

7.4 Restricted Live Streaming

• Minors may view age-appropriate live streams but cannot initiate their own broadcasts.
• Additional safeguards are applied when minors view live streams, including restricted chat participation and inability to send gifts or payments to streamers.

7.5 Restricted Payment Features

• Users under 18 cannot send or receive payments through BakkMe.
• Users under 18 cannot create fundraising campaigns or access creator monetization features.
• Users under 18 cannot purchase or send virtual gifts, tips, or donations.
• These restrictions are enforced at the system level and cannot be overridden by user settings.

7.6 Content Sensitivity Controls

• Sensitive content filters are enabled by default for users under 18 and cannot be fully disabled.
• Content warnings and interstitial screens are applied to potentially age-inappropriate content.
• Algorithmic recommendations for minors are tuned to reduce exposure to mature, violent, or otherwise inappropriate content.

7.7 Safety Prompts and Nudges

• Minors receive safety prompts when interacting with accounts that exhibit potentially concerning patterns.
• Before sharing personal information (such as location), minors receive educational safety warnings.
• Usage time notifications encourage healthy engagement patterns for younger users.

8 Parental Controls and Guidance

BakkMe recognizes that parents and guardians play a vital role in keeping children safe online. We provide tools and resources to support families in managing their children's online experience.

8.1 Parental Oversight Tools

• Family Center: Parents and guardians can link their BakkMe account to their child's account through our Family Center feature, allowing them to view their child's privacy settings, manage who can contact their child, and set usage time limits.
• Activity summaries: Parents of linked accounts receive periodic summaries of their child's platform activity, including time spent, new followers, and content interaction patterns (without revealing specific message contents, to balance safety with age-appropriate privacy).
• Privacy setting management: Parents can manage key privacy settings on their child's account, including contact restrictions and content visibility.
• Screen time controls: Parents can set daily usage limits and schedule "break" times for their child's BakkMe usage.

8.2 Parental Guidance Resources

• BakkMe provides an online Parent and Guardian Guide with information about platform features, safety settings, and tips for discussing online safety with children.
• We publish regular safety advisories and updates when new features or policies are introduced that affect younger users.
• Links to external parenting and digital safety resources from trusted organizations (e.g., Family Online Safety Institute, ConnectSafely, Internet Matters).

8.3 Parental Reporting and Requests

• Parents and guardians can contact BakkMe at safety@bakkme.com to report concerns about their child's account or interactions on the platform.
• Parents may request the deletion of their child's account and associated data at any time.
• If a parent discovers their child under 13 has created an account, they can request immediate account removal, and BakkMe will delete the account and all associated data within 48 hours.

9 Education and Awareness

BakkMe believes that education and awareness are essential components of an effective child safety strategy. We invest in proactive initiatives to educate users, families, and the broader community.

9.1 User Education

• Onboarding safety information: All new users, particularly those under 18, receive age-appropriate safety information during the onboarding process, including how to manage privacy settings, block and report users, and recognize concerning behavior.
• In-app safety center: BakkMe maintains a dedicated Safety Center within the app with articles, videos, and interactive resources about online safety, digital literacy, and healthy online relationships.
• Periodic safety reminders: Users under 18 receive periodic in-app notifications with safety tips and reminders about available safety tools.

9.2 Community Awareness

• BakkMe participates in and promotes awareness campaigns such as Safer Internet Day, Child Safety Week, and Anti-Bullying Week.
• We publish educational content on our blog and social media channels to raise awareness about online child safety issues.
• We partner with schools, youth organizations, and child safety nonprofits to develop and distribute educational materials.

9.3 Creator and Influencer Responsibility

• Creators and influencers on BakkMe are provided with specific guidance on child safety responsibilities, including content creation best practices when minors may be in their audience.
• Creators are prohibited from targeting content to children that is inappropriate for their age group.
• Creators who regularly interact with younger audiences are subject to additional monitoring and may be required to complete child safety training.

10 Data Protection for Children

BakkMe applies enhanced data protection measures for children in compliance with COPPA, GDPR, the UK Children's Code, and other applicable data protection laws.

10.1 Data Collection Minimization

• We collect only the minimum personal data necessary to provide the service to users under 18.
• Precise geolocation data is not collected from users under 18.
• Profiling of minors for advertising or commercial purposes is prohibited.
• Behavioral tracking for personalized advertising is disabled for users under 18.

10.2 Data Usage Restrictions

• Personal data of minors is not shared with third-party advertisers or data brokers.
• Data belonging to minors is not used to build marketing profiles or for targeted advertising.
• Algorithmic systems that process data of minors are designed and configured to prioritize their best interests, in line with the UK Age Appropriate Design Code.
• Any data processing involving minors undergoes a Data Protection Impact Assessment (DPIA) and a Child Rights Impact Assessment.

10.3 Data Retention and Deletion

• Personal data of minors is retained only for as long as necessary to provide the service and comply with legal obligations.
• When a minor's account is deleted, all associated personal data is permanently deleted within 30 days, except where retention is required by law (e.g., evidence preservation for CSAE investigations).
• Data of users who fail age verification (i.e., are determined to be under 13) is deleted immediately and is not retained.

10.4 Default Privacy Settings

11 Live Streaming Safety

Live streaming presents unique child safety challenges due to its real-time nature. BakkMe implements specific safeguards to protect children in the context of live content.

11.1 Age Restrictions

• Hosting live streams: Only users aged 18 and over may host live streams on BakkMe. Age verification is required before a user can access live streaming broadcasting capabilities.
• Viewing live streams: Users under 18 may view live streams that are classified as appropriate for their age group. Streams flagged as containing mature content are blocked for minors.

11.2 Real-Time Moderation

• AI-powered monitoring: All live streams are monitored in real-time by automated systems that use computer vision, audio analysis, and natural language processing to detect potentially harmful content, including content involving minors.
• Automatic interruption: If the system detects a minor appearing in a live stream in a potentially unsafe context, the stream may be automatically paused or terminated pending human review.
• Chat moderation: Live stream chat is monitored for CSAE-related content, grooming language, and inappropriate comments directed at minors. Offending messages are removed automatically and the sender is flagged for review.

11.3 Live Stream Reporting

• A prominently displayed report button is available at all times during a live stream.
• Reports related to child safety during live streams are treated as the highest priority and trigger immediate human review.
• BakkMe retains recordings of all live streams for a minimum period to support review and investigation of reported content.

11.4 Gift and Payment Restrictions

• Users under 18 cannot send gifts, tips, or payments to live streamers.
• Payments or gifts from users exhibiting suspicious patterns (e.g., frequently targeting streams featuring young users) are flagged for review.

12 Chat and Messaging Safety

Private messaging and group chat features require specific safeguards to protect minors from grooming, exploitation, and exposure to inappropriate content.

12.1 Contact Restrictions for Minors

• By default, only mutual followers can send direct messages to users under 18.
• Adults who are not mutual connections cannot initiate direct conversations with minors.
• Group chat invitations to minors from users they do not follow are restricted.
• Message requests from accounts flagged for suspicious behavior are automatically blocked from reaching minors.

12.2 Content Scanning in Messages

• Images and videos shared in direct messages and group chats are scanned for CSAM using hash-matching technology and AI classifiers.
• Links shared in messages are checked against known CSAM distribution databases.
• Text-based grooming detection systems analyze messaging patterns where one party is a minor and the other is an adult, to identify potentially predatory conversations.

12.3 Safety Prompts in Messaging

• When a minor receives a message from an adult who is not a mutual connection, a safety prompt is displayed before the message content is revealed, advising the minor to be cautious and providing a one-tap option to block and report.
• If a conversation is flagged by automated systems as potentially concerning, the minor receives a contextual safety notification with links to help resources and reporting tools.
• Users under 18 are shown periodic reminders within the messaging interface about how to report uncomfortable conversations and access help.

12.4 Group Chat Safeguards

• Group chats containing minors are subject to enhanced moderation, including stricter content filters and behavioral monitoring.
• Minors cannot be added to groups that have been flagged for containing adult or inappropriate content.
• Group administrators are notified of their responsibility to maintain a safe environment when minors are members of their group.

13 Staff Training and Compliance

Effective child safety requires well-trained and supported personnel. BakkMe invests significantly in the training, development, and well-being of all staff involved in child safety operations.

13.1 Mandatory Training Programs

• All employees: Every BakkMe employee, regardless of role, completes mandatory child safety awareness training upon hiring and annually thereafter. This training covers recognizing CSAE, reporting obligations, and the company's zero-tolerance policy.
• Moderation and trust & safety teams: Specialized, in-depth training covering CSAM identification, grooming detection, trauma-informed content review, legal reporting requirements, evidence preservation, and interaction with law enforcement. Training is updated at least every six months.
• Engineering and product teams: Training on safety-by-design principles, implementing child safety features, age-appropriate design, and privacy-preserving detection technologies.
• Customer support: Training on handling child safety reports with sensitivity, escalation procedures, and directing reporters to appropriate internal teams and external resources.

13.2 Background Checks

• All employees and contractors with access to user content, child safety systems, or user data undergo thorough background checks prior to employment.
• Positions involving direct handling of CSAE content or child safety investigations require enhanced background screening.

13.3 Staff Well-Being

• BakkMe provides mandatory and confidential mental health support for all staff exposed to CSAE content, including access to specialized counselors, regular wellness check-ins, and structured debriefing sessions.
• Content review shifts involving CSAE material are limited in duration to reduce psychological impact.
• Staff may request reassignment from CSAE-related duties at any time without professional penalty.

13.4 Compliance and Oversight

• BakkMe appoints a designated Child Safety Officer responsible for overseeing the implementation and effectiveness of all child safety policies and procedures.
• Regular internal audits are conducted to ensure compliance with this policy, applicable laws, and industry best practices.
• BakkMe engages independent third-party auditors to periodically assess the effectiveness of our child safety program.
• Findings from audits and reviews are reported to senior leadership and acted upon promptly.

14 Transparency Reporting

BakkMe is committed to transparency about our child safety efforts. We publish regular reports to inform the public, regulators, and stakeholders about our work to protect children on the platform.

14.1 Regular Transparency Reports

BakkMe publishes a Child Safety Transparency Report at least annually, which includes:

• The number of CyberTipline reports filed with NCMEC.
• The volume of CSAM and CSAE-related content detected and removed, broken down by detection method (automated vs. user report vs. human review).
• The number of accounts terminated for child safety violations.
• The number of law enforcement requests received and responded to in relation to child safety.
• The number of child safety reports received from users and average response times.
• Investments in child safety technology, staffing, and programs.
• Key initiatives and partnerships undertaken during the reporting period.

14.2 Regulatory Compliance Reporting

• BakkMe complies with all mandatory reporting requirements under the EU Digital Services Act, UK Online Safety Act, and other applicable regulatory frameworks.
• We respond promptly to requests for information from regulatory bodies, including Ofcom (UK), the European Commission, and the Federal Trade Commission (US).

14.3 Industry Collaboration

• BakkMe participates in industry initiatives and working groups focused on child safety, including the Technology Coalition, WePROTECT Global Alliance, and the ICT Coalition for Children Online.
• We share threat intelligence (such as CSAM hash lists) with other platforms and organizations, in accordance with legal requirements, to prevent the spread of CSAE content across the internet.
• BakkMe contributes to the development of industry standards and best practices for child safety.

15 Updates and Review Process

Child safety is a continuously evolving challenge. BakkMe commits to regularly reviewing and updating this policy and our associated practices to reflect new threats, technologies, legal requirements, and best practices.

15.1 Regular Review Cycle

• This Child Safety Standards document is reviewed and updated at minimum on an annual basis.
• Additional reviews are triggered by significant events, including changes in applicable law, emerging threats or attack vectors, platform feature launches, and findings from internal or external audits.
• Each review involves input from child safety specialists, legal counsel, product and engineering teams, and external advisors.

15.2 Change Notification

• Material changes to this policy are communicated to users through in-app notifications and/or email.
• A changelog is maintained to document all revisions, with the date and nature of each change.
• The current version and effective date are always displayed at the top of this document.

15.3 Continuous Improvement

• BakkMe monitors developments in child safety technology, research, and regulation to proactively identify opportunities for improvement.
• We solicit feedback from child safety experts, advocacy organizations, and regulators to inform policy and product improvements.
• Lessons learned from incidents, enforcement actions, and audits are systematically incorporated into our policies and systems.

16 Contact Information and Emergency Resources

16.1 BakkMe Contact Channels

16.2 External Reporting and Support Resources

16.3 Mental Health and Support Resources