creoviva Child Safety & Illegal Content Policy

Draft v1.0 · Effective date: TBD · Last updated: TBD

This Policy sets out creoviva's operational approach to child safety, illegal content, user reports, moderation, evidence preservation and cooperation with competent authorities. It complements the creoviva Terms of Service and Privacy Policy.

1. Scope and responsibility

creoviva is operated by Ember Eagle Ltd, England and Wales. The company will designate an accountable person/team for online safety, moderation and law-enforcement response. Contact details: TBD (safety), TBD (legal), TBD (escalation).

creoviva itself does not create or publish adult content. Each creator has their own individual public creator page on which they make available their own sessions and videos, subject to this Policy and the Terms of Service.

2. 18+ service and age assurance

• creoviva's age-restricted functionality is intended for adults aged 18 and over.
• Creators must complete the required identity and age verification before relevant creator functionality is enabled.
• Every creator page offering adult content shows a mandatory 18+ gate before any session, video, thumbnail or description on that page is displayed.
• creoviva will use proportionate age-assurance measures appropriate to the services and jurisdictions in scope.
• Accounts may be restricted where age or identity cannot be satisfactorily established.
• creoviva will not knowingly allow minors to operate creator accounts or access age-restricted creator functionality.

3. Zero tolerance categories

• Child sexual abuse material (CSAM) and child sexual exploitation material.
• Sexualised depictions of minors or content facilitating sexual abuse of children.
• Child grooming or sexual solicitation of a minor.
• Trafficking, sexual exploitation, forced sexual activity or coercive sexual conduct.
• Non-consensual intimate imagery and sexual content shared without valid consent.
• Sexual content involving persons unable to provide valid consent.
• Content or conduct that facilitates criminal activity.
• Fraud, identity theft, impersonation or attempts to circumvent safety and age controls.

4. Detection and reports

Potentially illegal or prohibited content may be identified through user reports, creator/customer complaints, moderation review, automated safety tools, hash matching where available, security systems, trusted third-party notifications or lawful requests.

creoviva does not rely on a single detection method. Automated tools may support triage but do not replace appropriate human review.

5. Immediate response

Where a report or detection indicates a serious safety or criminal concern, creoviva may immediately:

• Restrict access to the relevant content, account, session, messaging or other functionality while the matter is assessed.
• Prevent further distribution where technically possible.
• Preserve relevant evidence and metadata where legally justified.
• Restrict or suspend the associated account.
• Escalate to the designated safety/legal team.
• Assess whether a report to a competent authority is required or appropriate.

6. CSAM and child exploitation

creoviva applies a zero-tolerance approach to CSAM and child sexual exploitation. Where creoviva detects CSEA content that falls within an applicable reporting duty, it will make the required report through the applicable reporting mechanism.

For a UK-based provider subject to the relevant Online Safety Act duty, Ofcom states that regulated user-to-user services must report detected and unreported CSEA content to the National Crime Agency (NCA), subject to the applicable rules. The duty commenced for regulated user-to-user services on 7 April 2026. Where a provider is outside the UK, Ofcom states that the duty concerns UK-linked CSEA content. creoviva will obtain legal advice on whether and how these duties apply to its exact service.

Where an equivalent foreign reporting route has already received the relevant report, creoviva will avoid duplicate reporting where the applicable rules permit or require this.

7. Evidence preservation

When legally justified, creoviva may preserve information necessary for safety investigations, legal compliance, law-enforcement cooperation, dispute resolution or the establishment, exercise or defence of legal claims, including:

• Account identifiers and registration information.
• Relevant content identifiers and metadata.
• Upload/access timestamps and technical logs.
• Messages or reports relevant to the incident.
• Moderation decisions and reasons.
• Information required by a lawful preservation or disclosure request.

creoviva will not retain information indefinitely and will apply its retention schedule and applicable data-protection requirements.

8. Law-enforcement cooperation

creoviva may disclose personal data and relevant records to police, prosecutors, child-protection authorities, regulators or other competent authorities where required by law, pursuant to valid legal process, or where a lawful basis permits disclosure to protect users or prevent serious harm.

Emergency situations involving an immediate threat to life or serious harm will be escalated through appropriate emergency channels.

9. User reporting

Users can report illegal content, suspected child exploitation, non-consensual intimate imagery, trafficking, threats, fraud or other serious violations through the "Report illegal content" link on the relevant creator page.

• Identify the profile, content, session or conversation if possible.
• Explain why the material or conduct appears unlawful or unsafe.
• Do not download, copy or redistribute suspected CSAM.
• Do not attempt to investigate or confront a suspected offender.

10. Moderation decisions

creoviva may remove or restrict content, prevent publication, suspend accounts, terminate accounts, restrict live sessions or messaging, or impose other proportionate measures.

Where required by applicable law, users will be provided with information about relevant decisions and available complaint or appeal mechanisms.

11. Appeals and complaints

A user whose content or account has been restricted may contact TBD (appeals). Appeals should identify the decision and provide relevant context. Appeals concerning illegal content may be limited where disclosure of information would compromise an investigation, reveal confidential safety systems, or be prohibited by law.

12. Creator obligations

• Creators must ensure that every person appearing in their content is an adult and has provided all legally required consent.
• Creators must maintain appropriate records supporting age and consent where required.
• Creators must not upload content they do not have the right to use.
• Creators must comply with all applicable criminal, privacy, copyright, consent and online-safety laws.
• Creators must cooperate with reasonable safety investigations.

13. Privacy and confidentiality

Safety investigations involve personal data. Processing will be governed by the creoviva Privacy Policy and applicable data-protection law. Access to sensitive safety information will be restricted to authorised personnel and service providers with a legitimate need to access it.

14. Training and governance

creoviva should maintain documented moderation and escalation procedures and provide appropriate training to personnel responsible for safety decisions. Material safety incidents and regulatory changes should be reviewed by the responsible management function.

15. Review

This Policy should be reviewed at least annually and whenever there is a significant change to creoviva's functionality, user base, legal obligations, moderation systems or risk profile.

16. Contact

Safety / illegal content: TBD
Legal: TBD
Appeals: TBD
Registered office: 71-75 Shelton Street, WC2H 9JQ London, United Kingdom
Company number: TBD