Circle CSAE Policy

Effective date:  1 July 2025

Introduction

This Circle SCAE Policy is dedicated to creating a safe digital environment for all users. We maintain a zero-tolerance approach toward any form of child sexual abuse and exploitation (CSAE). This SCAE Policy outlines our responsibilities, preventive measures, and the steps taken to ensure that our App remains free from content and activities that contribute to CSAE. Our SCAE Policy aligns with international legal standards and best practices to ensure a safe and responsible online environment for all users.

Scope

This SCAE Policy covers all services provided by Circle, including user interactions, messaging, listings, and user-generated content (UGC). This policy applies to all users, partners, and service providers interacting with or through the App.

Definitions

Child - any individual under the legal age of majority as defined by the relevant jurisdiction (typically under 18 years of age, or under 13 years in contexts specifically mentioned).

Child Sexual Abuse (CCA) – any sexual activity, abuse or exploitation (real or attempted) that involves a child.

Exploitation – the act of using a child for sexual purposes, including the production, distribution or possession of explicit sexual content involving a child.

Preventative and Reporting Measures

-          Age Gating

The Circle’s App is intended for users above the minimum age threshold specified in our Privacy Policy. We do not knowingly collect personal information from children under 18.

Systems are in place to verify use age during account creation and periodically during App use.

-          Automated Monitoring

We use AI-powered moderation tools and industry-standard detection technologies to identify and remove illegal content.

-          User Reporting Tools

Users can report CSAE content or suspicious behavior directly within our App. Reports are reviewed promptly.

-          Dedicated Review Team

Our trained moderation team investigates all CSAE reports and takes immediate action.

-          Law Enforcement Notification

Confirmed CSAE cases are reported to relevant authorities, including law enforcement organisations. All incidents are managed per local and international child protection laws.

 

Enforcement Actions

Circle takes strict action against users who violate the Circle CSAE Policy, including:

-          Immediate removal of violating content.

-          Permanent banning of offending accounts.

-     Reporting violations to law enforcement and relevant child protection agencies.

 

Legal Compliance and Accountability

This policy complies with Regulation (EU) 2021/1232, which governs the detection, removal, and reporting of CSAE-related content in digital services.

How to Report CSAE Content

If you encounter any CSAE content on Circle App, report it immediately using our in-app reporting tools or contact us at info@circle.com.ua.  We also encourage users to report suspected CSAE content to respective local authorities.

Circle strives to maintain a safe, responsible, and accountable digital environment for all our users. We will continue to enhance our policies, tools, and enforcement measures to prevent CSAE and protect children.

This SCAE Policy is reviewed annually or upon significant App changes.  Changes are made available to all users.