Version: 0.1 (draft for advocate review)
In short
- Privé is for adults 18+ only. Children may not use it, and may not appear in any Content.
- We have zero tolerance for child sexual abuse material (CSAM) and for child sexual abuse and exploitation (CSAE), including grooming and sextortion.
- We remove such Content, ban the accounts involved, preserve evidence and report to the authorities: in India through cybercrime.gov.in and the police, and to NCMEC where applicable.
- Report concerns in the App (reason "underage"), or directly to our child safety contact.
- This Policy is our published standard against CSAE, as Google Play requires.
1. Who we are
Privé is operated by POLYMATH COGNITIVE, a partnership firm with its registered office at S-300-H, Scheme 4-S, Macheda, Jaipur, Rajasthan, India (Sanstha Aadhaar Number (Rajasthan): 8005220006002779). Defined terms are as in the Terms of Service.
2. Definitions
- "Child" or "minor" means anyone under 18.
- "CSAM" means any visual depiction, including AI-generated or altered images, of a child engaged in sexually explicit conduct, or in a sexualised way. This includes "child sexual abuse material" and "child pornography" as defined in the Protection of Children from Sexual Offences Act, 2012 ("POCSO") and section 67B of the IT Act.
- "CSAE" means child sexual abuse and exploitation of any kind. This includes:
- grooming;
- sexualising a child;
- sextortion;
- trafficking;
- soliciting a child;
- distributing or requesting CSAM.
3. 18+ only
3.1 Sign-up. Every User must confirm at sign-up that they are 18 or older. We record that confirmation. Accounts created before this confirmation was introduced must confirm before they can pay for or start anything.
3.2 Creators are reviewed by us before approval, and must give PAN and Aadhaar before their first payout.
3.3 Content. Every person appearing in Content must be 18 or older. Creators must hold proof of age and consent for everyone in their Content.
3.4 Suspected minors. If we have reason to believe a User is a minor, we suspend the account and may ask for proof of age.
4. What is prohibited
On Privé you must not:
- upload, send, stream, request, link to or store CSAM;
- sexualise a child in any way, including in text, comments, drawings or AI-generated media;
- contact a child for sexual purposes, groom a child, or arrange to meet one;
- threaten to share intimate images of a child, or coerce a child (sextortion);
- promote, normalise or provide guidance on CSAE;
- involve a child in any Content, call or live, even if it is not sexual. Children may not appear in Privé at all.
5. How to report
5.1 Report in the App. Report a post with the reason "underage", or report and block the user from their profile or chat.
5.2 Child safety contact. Our Grievance Officer, at hi@prive.buzz (phone to be published). This person is our designated point of contact for child safety, including for Google Play.
5.3 Report directly to the authorities.
- India: the National Cyber Crime Reporting Portal (cybercrime.gov.in), the cyber-crime helpline 1930, or your local police.
- Child in danger in India: call 112, or Childline 1098.
- Elsewhere: the NCMEC CyberTipline (report.cybertip.org), or your local hotline listed by INHOPE.
5.4 Do not copy. Do not screenshot, download or forward suspected CSAM, even to report it. Report its location instead.
6. What we do
6.1 Response. When we learn of suspected CSAE, we:
- remove or disable the Content as fast as possible, and within 24 hours at most;
- suspend the accounts involved, and permanently ban them where it is confirmed;
- preserve the Content and related records (section 7);
- report to the authorities as the law requires:
- in India, to the police, as POCSO section 19 requires, and through cybercrime.gov.in;
- to NCMEC, where we have a reporting obligation or a reporting arrangement;
- cooperate with law-enforcement requests.
We do not notify the suspect where that could prejudice an investigation.
6.2 Detection. We act on User reports and staff review.
7. Preservation
7.1 What we keep. We keep records for at least 180 days, or longer if an authority asks or an investigation requires it, in line with Rule 3(1)(g) of the IT Rules. The records include:
- the removed Content;
- account details;
- IP addresses;
- message and payment records;
- our actions.
7.2 Access. Access is restricted to authorised staff, and every access is logged.
8. Staff
Staff who review child-safety reports receive guidance on handling such material and are given access only as needed.
9. Appeals
Accounts banned for CSAE that is confirmed are not reinstated. If you believe an underage-related suspension was a mistake, you can appeal under the Grievance Redressal Policy, with proof of age.
10. Changes
We review this Policy at least once a year, and update it when the law or app-store standards change.