Child Safety Standards Policy

The Operator prohibits child sexual abuse material ("CSAM"), child sexual abuse and exploitation ("CSAE"), grooming, sextortion, child trafficking and any content or conduct that sexualises or endangers a minor (a person under eighteen (18), or under the higher age of majority that applies), whether the content is real, synthetic, altered, animated or generated by artificial intelligence. This prohibition applies to every part of the Services and to all Users without exception.

2.1 Flowence and Alayrix are business tools for adults. The Services are not directed to, designed for or marketed to children, and Users must be at least eighteen (18) years old.

2.2 The Operator does not knowingly allow minors to hold accounts. If the Operator learns that an account is held by a minor, it will suspend and delete the account and associated data, except where preservation is legally required.

2.3 Customers who handle content showing or concerning minors (for example a school, a youth organisation or a brand with a child audience) remain responsible for lawful consent, for lawful content and for compliance with children's privacy and advertising laws, and must notify the Operator in advance as stated in the Master Subscription Agreement.

Users must not use the Services to create, upload, store, generate, share, request, advertise or link to: (a) CSAM or CSAE content in any form; (b) sexualised depictions of minors, including AI-generated, synthetic, cartoon or illustrated depictions; (c) content that grooms, solicits or attempts to establish sexualised or exploitative contact with a minor; (d) sextortion or blackmail involving minors; (e) content promoting or facilitating child trafficking, child marriage or child abuse; (f) content that identifies a victim of child abuse in a way that exposes them to harm; (g) marketing or commercial content that is inappropriate for minors and targeted to them; or (h) any instructions for locating, obtaining or evading detection for any of the above.

The AI Features and AI-assisted Services must not be used to generate or modify any sexual or exploitative depiction of a minor. The Operator applies prompt and output safeguards and may block, log for safety purposes, and report prohibited requests. Attempts to bypass those safeguards are a violation of this Policy and may be reported to authorities.

5.1 The Operator uses a combination of measures proportionate to its Services, which may include: hash-matching against industry databases of known CSAM (where integrated), automated classifiers and keyword filters for text and image uploads, account and behaviour signals, human review of flagged content by trained personnel, and review of reports received through the channels in clause 6.

5.2 Content moderation personnel receive training on identifying and handling CSAM and CSAE, on escalation, and on evidence handling, and are offered appropriate wellbeing support.

5.3 The Operator reviews the effectiveness of its measures at least annually, and updates them to reflect new risks, legal requirements and platform policies.

6.1 In the app. Every Mobile Application provides a Report function on content and user profiles (Report, Child safety concern) so that Users can flag concerns without leaving the application, and a way to block other users.

6.2 Other channels. Any person may report concerns to services@alayrix.com, or through the contact form on the Flowence website. Reports may be made anonymously.

6.3 What to include. A report should include the content location (URL, account identifier or screenshot), the reason for concern and, if the reporter wishes, contact details. Reporters must not forward CSAM to the Operator, and should instead describe its location, because possession and distribution of CSAM may be an offence. The Operator will accept reports of the existence and location of CSAM.

6.4 Reporters in good faith. The Operator will not take adverse action against a person who makes a report in good faith.

7.1 Timing. The Operator will acknowledge a child-safety report within one (1) Business Day. Reports of apparent CSAM, CSAE or imminent risk to a child are escalated immediately and reviewed within twenty-four (24) hours, and content is removed or disabled as soon as it is verified, and ordinarily within the same twenty-four (24) hours.

7.2 Actions. The Operator will: (a) remove or disable access to the content; (b) preserve the content, associated metadata and account information securely, to the extent the law permits and requires, for the period required for law enforcement; (c) suspend and permanently terminate the responsible accounts without refund and without prior warning; (d) prevent the User from re-registering where reasonably possible; and (e) make a report to the competent authorities under clause 8.

7.3 No tipping off. The Operator does not generally notify the person under investigation where doing so could prejudice an investigation or place a child at risk, or where it is legally prohibited.

8.1 The Operator complies with applicable child-protection laws and will report apparent CSAM and CSAE to the competent authorities in accordance with them, including: (a) in the United States, to the National Center for Missing and Exploited Children (NCMEC) CyberTipline under 18 U.S.C. section 2258A; (b) in Canada, to the Canadian Centre for Child Protection (Cybertip.ca) and law enforcement under the Act respecting the mandatory reporting of Internet child pornography by persons who provide an Internet service; (c) in the European Union, to national authorities and in accordance with Regulation (EU) 2022/2065 (Digital Services Act) and the rules on preventing and combating child sexual abuse that apply from time to time; (d) in the United Kingdom, to the National Crime Agency or the Internet Watch Foundation, and in accordance with the Online Safety Act 2023 where applicable; (e) in Australia, to the eSafety Commissioner and the Australian Federal Police, and in accordance with the Online Safety Act 2021 and the industry codes and standards; (f) in Pakistan, to the Federal Investigation Agency (National Cyber Crime Investigation Agency) and other competent authorities in accordance with the Prevention of Electronic Crimes Act, 2016; (g) in the Middle East and South East Asia, to the competent national authorities; and (h) to the relevant app store operator where required.

8.2 The Operator cooperates with valid law-enforcement requests, preserves evidence as the law requires and does not use reporting obligations as a reason to retain data longer than necessary.

The Operator does not knowingly collect Personal Data from children for its own purposes. Where a minor's Personal Data comes to its attention, it is handled in accordance with the Privacy Policy, deleted unless it must be preserved for child-protection reasons, and not used for marketing or profiling.

The child safety point of contact reports to senior management, maintains records of reports and actions, reviews this Policy at least annually, and is responsible for ensuring compliance with Google Play's Child Safety Standards policy, the Apple App Store Review Guidelines (including those on user-generated content and kids) and applicable law. The Operator may publish transparency information about its child-safety enforcement.

If a child is in immediate danger, contact local emergency services. Reporting resources include the NCMEC CyberTipline (report.cybertip.org), Cybertip.ca, the Internet Watch Foundation (report.iwf.org.uk), the eSafety Commissioner (esafety.gov.au), and, in Pakistan, the FIA National Cyber Crime Investigation Agency.

This Policy may be updated to reflect changes in law and practice, and the current version is available at all times at the address where it is published. Contact: services@alayrix.com; postal address: BnR360, H#C-40, Karachi University Staff Town, Karachi, Pakistan.