Child Safety Standard

1. Designated child safety point of contact

1.1 Excluvia maintains a designated point of contact for all child safety matters.

1.2 Email: safety@excluvia.com

1.3 This address is monitored and reports received through it are prioritised above all other reports.

1.4 The address may be used by users, parents and guardians, child protection organisations, regulators and law enforcement.

2. Zero tolerance

2.1 Eclatit Limited, which operates Excluvia, enforces a zero-tolerance policy on child sexual abuse and exploitation ("CSAE") and child sexual abuse material ("CSAM") across the platform

and all associated services.

2.2 Any attempt to create, upload, solicit, stream, distribute or facilitate access to content involving child exploitation, abuse, grooming, sextortion or the sexualisation of a minor results in immediate and permanent account termination and referral to law enforcement.

2.3 This applies to every part of the Services without exception: posts, comments, profiles, direct messages, digital products, courses and livestreams.

2.4 These standards are given effect by clause 3.1(a) of our Acceptable Use Policy and clause 4 of our Community Guidelines, which form part of our Terms of Use.

2.5 A "minor" means anyone under eighteen years of age, or anyone treated as a minor under the law applying to them, whichever gives greater protection.

3. Prohibited conduct and content

3.1 The following are prohibited absolutely:

(a) Child sexual abuse material. Generating, uploading, sharing, requesting, linking to or possessing any visual, textual or audio depiction of child sexual abuse or exploitation, including material that is drawn, animated, computer-generated or produced using artificial intelligence.

(b) Grooming and predatory behaviour. Communicating with, soliciting or building a relationship with a minor for the purpose of sexual exploitation or abuse, including attempts to move a conversation to another service for that purpose.

(c) Sextortion and blackmail. Threatening or coercing a minor into providing intimate images, money, or personal information.

(d) Sexualisation of minors. Any content depicting or describing a person under eighteen in a sexually suggestive, exploitative or explicit context.

(e) Child trafficking. Facilitating or promoting the recruitment, transport, harbouring or commercial sexual exploitation of a child.

(f) Facilitation. Advertising, signposting, coded language, or any other means of helping another person access or produce material described in this section.

3.2 Excluvia does not permit adult content of any kind, which is a separate prohibition set out in clause 4 of the Acceptable Use Policy.

4. Age eligibility

4.1 Excluvia is strictly for people aged eighteen or over. Minors may not register, hold an account, post content,make purchases, appear in content, or take part in livestreams.

4.2 We collect a date of birth at registration and do not allow registration to complete where the date given shows the person to be under eighteen.

4.3 Where we become aware that an account holder is under eighteen, we close the account and delete their personal data other than anything we are required to retain by law.

4.4 Where we become aware that a person under eighteen appears in content on the platform, we remove the content and investigate the account that published it.

4.5 Creators are responsible for ensuring that everyone appearing in their content, including guests and co-hosts in livestreams, is over eighteen and has consented. This is set out in clause 17 of the Creator Agreement and clause 5 of the Livestreaming Terms.

5. How we detect prohibited content

5.1 Automated moderation of posted content. Content uploaded to Excluvia is scanned automatically using Sightengine, a specialist content moderation service. This covers images and video posted to the platform, and flags material including nudity, sexual content and content involving minors.

5.2 Human review. Content flagged by automated moderation is reviewed by our moderation team. Any decision to remove content or terminate an account for a child safety reason involves a person.

5.3 User reporting. Every post, profile, message and livestream can be reported from within the app. Reports categorised as child safety are routed directly to the designated contact and prioritised above all other reports. Anyone may report, including people without an account.

5.4 Livestreams. Automated scanning is not currently applied to live video. Live content is monitored through user reporting during broadcast and through review of recordings afterwards. We record livestreams and retain recordings for a limited period, which allows us to investigate reports made during or after a broadcast. We may end a livestream immediately and without notice.

5.5 Account signals. We monitor for behaviour associated with predatory conduct, including patterns of contact, attempts to move conversations off the platform, and accounts created after a previous account was terminated.

5.6 We keep our detection capability under review and are working to extend automated moderation to live video.

6. Reporting to authorities

6.1 Where we identify or receive a report of CSAE or CSAM, we report it to the appropriate authorities.

6.2 Excluvia is operated from Nigeria with a subsidiary in the United Kingdom, and we report through the routes available in those jurisdictions and internationally:

(a) the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) in Nigeria;

(b) the Nigeria Police Force National Cybercrime Centre;

(c) the Internet Watch Foundation, for material accessible in or originating from the United Kingdom;

(d) the National Crime Agency, through CEOP, where a child in the United Kingdom is at risk; and

(e) law enforcement in any other country where a child appears to be at risk or an offender appears to be located.

6.3 Where a child appears to be at immediate risk of harm, we escalate to law enforcement without waiting for our investigation to conclude.

6.4 We cooperate fully with law enforcement and respond to valid legal requests for information.

6.5 We do not notify a user that they have been reported to law enforcement where doing so would prejudice an investigation or place a child at risk.

7. What happens when we find prohibited content

7.1 On receipt of a child safety report, or on detection:

(a) the content is removed from the platform immediately and access to it is blocked;

(b) the account is suspended immediately, pending investigation; and

(c) any livestream in progress is ended.

7.2 These steps are taken on receipt, before the investigation is complete. We do not leave suspected material accessible while we review it.

7.3 Investigation. We complete our investigation within two to three business days of the report. Where a child appears to be at immediate risk, we act on that immediately and do not wait.

7.4 Where a report is substantiated:

(a) the account is permanently terminated;

(b) associated accounts are identified and terminated;

(c) any earnings derived from the prohibited conduct are withheld and not paid; and

(d) the matter is reported under section 6.

7.5 Evidence preservation. Removal from the platform does not mean destruction. We securely preserve the content, account records, communications and technical data associated with a substantiated report, in a restricted-access system, so that it is available to law enforcement. We retain it for as long as required by law, or for as long as an investigation or proceedings continue, whichever is longer. Access is limited to those who need it for that purpose.

8. Preventing return after termination

8.1 A person whose account is terminated for a child safety reason is permanently banned from Excluvia and may not create a new account.

8.2 We take measures to identify and block attempts to re-register, including matching against retained identifiers.

8.3 Creating a new account after termination is itself a breach of our Terms of Use and any such account is closed on discovery.

8.4 We do not restore an account terminated on child safety grounds save where section 9 applies.

9. Challenging a decision

9.1 A person whose account is terminated on child safety grounds may ask us to review the decision by writing to appeals@excluvia.com.

9.2 The account remains suspended throughout any review.

9.3 Reviews are conducted by a person who was not involved in the original decision. The threshold for reversal is high, and we reverse only where we are satisfied the original decision was wrong.

9.4 We do not review, and will not reinstate, an account terminated in relation to confirmed child sexual abuse material.

9.5 Nothing in this section delays or affects reporting under section 6.

10. Our people

10.1 Team members who review reported content receive guidance on identifying CSAE and on the escalation process.

10.2 Access to reported material is restricted to those who need it.

10.3 We recognise that this work is difficult and we support the people who do it.

11. Legal compliance

11.1 We comply with the child protection laws applying in the jurisdictions in which we operate, including the Child Rights Act and the Cybercrimes (Prohibition, Prevention etc.) Act in Nigeria, and the Protection of Children Act, the Sexual Offences Act and the Online Safety Act in the United Kingdom.

11.2 We comply with the child safety requirements of the app stores through which Excluvia is distributed.

11.3 Where the law of a country in which a user is located imposes a higher standard, we apply that standard.

12. Review

12.1 We review these standards at least annually, and whenever we make a significant change to the platform.

12.2 The current version is published on our website.

13. Contact

13.1 Child safety reports and enquiries: safety@excluvia.com

13.2 Law enforcement and regulators: safety@excluvia.com, marked urgent.

13.3 Excluvia is operated by ECLATIT LIMITED in Nigeria with company number 7403160 and in England and Wales by ECLATIT LIMITED with company number 15060493.

13.4 If a child is at immediate risk, contact your local emergency services first.