Child Safety Policy

1 Purpose & Scope

Cirql LLC ("Cirql," "we," "our," or "us") is committed to preventing the sexual abuse and exploitation of children on our platform. This policy outlines our approach to detecting, reporting, and removing child sexual abuse material (CSAM) and any conduct that endangers minors.

This policy applies to all users of Cirql, all content shared through the platform, and all features of the service including text, media, links, and any other form of communication.

2 Zero-Tolerance Policy

Cirql maintains an absolute zero-tolerance policy toward child sexual abuse and exploitation (CSAE) in any form. This commitment is unconditional and is not subordinate to any other platform feature, including encryption and privacy protections.

3 Definitions

For the purposes of this policy:

• Child / Minor: Any person under the age of 18.
• CSAM (Child Sexual Abuse Material): Any visual depiction of sexually explicit conduct involving a minor, as defined by 18 U.S.C. § 2256. This includes photographs, videos, digital or computer-generated images, and images that have been created, adapted, or modified to appear as though a minor is engaged in sexually explicit conduct.
• CSAE (Child Sexual Abuse and Exploitation): The broader category encompassing CSAM as well as grooming, solicitation, trafficking, sextortion, and any other conduct that sexually exploits or endangers a child.
• Grooming: Building a relationship with a minor for the purpose of sexual abuse or exploitation, including building trust, isolating the child, or desensitizing them to sexual content.
• Sextortion: Threatening to distribute intimate images of a minor, or using coercion to obtain such images.

4 Prohibited Conduct

The following activities are strictly prohibited on Cirql and will result in immediate action:

• Uploading, sharing, requesting, or distributing CSAM or any sexual content involving minors
• Soliciting sexual images, acts, or contact from or with any person known or believed to be a minor
• Engaging in grooming behavior toward minors, including through private messages, group posts, or any other platform feature
• Sharing links to external sites that host CSAM or facilitate child exploitation
• Using Cirql to arrange, facilitate, or promote the trafficking or commercial sexual exploitation of minors
• Engaging in sextortion or coercion targeting minors
• Creating, distributing, or possessing AI-generated, cartoon, or otherwise simulated sexual imagery of minors
• Using the platform to identify, locate, or target minors for any form of abuse
• Advocating for or normalizing sexual contact between adults and children

5 Detection & Enforcement

Cirql uses a combination of measures to detect and prevent CSAE on the platform:

5.1 Structural Safeguards

• Invite-only access: Cirql does not allow open registration. Every user must be invited by an existing trusted member, creating an accountable chain of trust.
• Invite graph tracing: We maintain a record of who invited whom, enabling us to rapidly identify and remove networks of bad actors.
• Small, trusted groups: Cirql is designed for families and close-knit groups, not mass public sharing. This inherently limits the platform's utility for large-scale distribution of illegal content.

5.2 Behavioral Signals

• Unusual patterns of account creation or invitation activity
• Reports from other users (see Section 7)
• Metadata anomalies that may indicate abuse of the platform

5.3 Human Review

Reports of potential CSAE are reviewed by designated members of the Cirql team and escalated to law enforcement and NCMEC as required by law.

6 Reporting to Authorities

Cirql complies fully with all applicable laws regarding the reporting of child sexual abuse material and exploitation, including:

• 18 U.S.C. § 2258A: As an electronic communication service provider, Cirql is required to report apparent violations involving CSAM to the National Center for Missing & Exploited Children (NCMEC) via the CyberTipline.
• Preservation of evidence: When we become aware of potential CSAM or exploitation, we will preserve all available evidence, including account information, metadata, IP addresses, and timestamps, for a minimum of 90 days or as required by law.
• Law enforcement cooperation: We will cooperate fully with law enforcement investigations related to CSAE, including responding to valid legal process (subpoenas, court orders, search warrants).

We do not notify the offending user of a report to NCMEC or law enforcement.

7 How to Report

If you encounter content or behavior on Cirql that you believe constitutes child sexual abuse or exploitation, please report it immediately using any of the following methods:

All reports of potential CSAE are treated with the highest priority. We will never retaliate against a user who makes a good-faith report.

If a child is in immediate danger, contact local emergency services first.

8 Consequences for Violations

Any user found to have violated this policy will face the following actions, which may be taken simultaneously:

• Immediate account termination without prior notice
• Permanent ban from Cirql and all associated services
• Reporting to NCMEC and relevant law enforcement agencies
• Preservation and disclosure of all available account data and activity to authorities
• Invite chain review: Investigation of the offending user's invite chain and associated accounts, with further action as warranted

Users who invited an offending user may also be subject to review and potential action if evidence suggests complicity or awareness.

9 Encryption & Child Safety

Cirql uses end-to-end zero-knowledge encryption to protect user privacy. We believe privacy is a fundamental right. However, we also recognize the following:

• Privacy is not a shield for criminal conduct. Encryption protects lawful communications. It does not grant immunity for the sexual abuse or exploitation of children.
• We act on what we can observe. While we cannot decrypt user content, we can and do act on metadata, behavioral signals, user reports, and any unencrypted information available to us.
• We cooperate fully with legal process. When presented with valid legal process, we provide all information in our possession, including account data, IP logs, device information, timestamps, and invite relationships.
• We reserve the right to take action. If we have reasonable grounds to believe an account is being used for CSAE based on available signals, we will terminate the account, report to authorities, and preserve all available evidence — regardless of whether we can access the encrypted content.

We are committed to evaluating and adopting safety technologies that can coexist with strong encryption as they become available and proven.

10 Age Requirements

Cirql is not directed to children under the age of 13, and we do not knowingly allow children under 13 to create accounts. In jurisdictions where a higher minimum age applies (such as 16 under GDPR), users must meet that threshold.

Because Cirql is invite-only, every new user is referred by an existing trusted member. If we learn that a user is under the applicable minimum age, we will terminate their account and delete their personal data promptly.

11 Transparency & Accountability

Cirql is committed to transparency in our child safety efforts:

• We will publish periodic transparency reports detailing the number of CSAE reports received, actions taken, and reports submitted to NCMEC and law enforcement.
• We will engage with child safety organizations and industry best practices to continuously improve our safeguards.
• We welcome feedback from child safety experts, researchers, and advocacy organizations.

12 Changes to This Policy

We may update this policy from time to time to reflect changes in law, best practices, or our own capabilities. When we do, we will update the effective date at the top of this document. Material changes will be communicated to users through the app or by email.

13 Contact Us

For questions about this policy or to report concerns related to child safety, please contact us at:

For emergencies involving a child in immediate danger, contact local emergency services (911 in the US). To report CSAM or exploitation, contact NCMEC at CyberTipline.org or 1-800-843-5678.

Cirql LLC is a Delaware limited liability company.