TrafficStars Child Sexual Abuse Material (CSAM) Policy

Effective Date: 10 April, 2025
Version: 1.0
Applies to: All users, publishers, advertisers, affiliates, employees and third-party service providers

1. Purpose and Commitment

TrafficStars is unwavering in its commitment to protecting children from any form of sexual exploitation or abuse. As a digital advertising platform serving various sectors including adult verticals, we recognize the elevated responsibility we carry to prevent our technology and services from being used to spread or promote Child Sexual Abuse Material (CSAM) or to facilitate grooming, trafficking, or the sexual exploitation of minors in any form.

This Policy sets forth the safeguards, enforcement measures, and reporting procedures implemented to ensure that our platform remains rigorously resistant to any attempt to disseminate or engage in illegal content involving minors. We maintain full compliance with all applicable laws, including The Prevention and Combating of Sexual Abuse, Sexual Exploitation of Children and Depiction of Child Sexual Abuse Material (Amendment) Law of 2025 (Cyprus), relevant European Union directives, and binding international treaties and obligations.

2. Definitions

• Child: Any person under the age of 18, in accordance with international human rights law and the UN Convention on the Rights of the Child.
  
• Child Sexual Abuse Material (CSAM): Any material in any form, including but not limited to visual, textual, AI-generated or audio representation—whether real, fictional, simulated, or digitally created—that:

• Depicts a child engaged in sexually explicit conduct or depicting a person who appears to be a child engaging in a real or simulated act of a sexual nature;
• Portrays the genitals organs of a child or of any person who appears to be a child for sexual purposes;
• Provides guidance, instructions, or indications intended to promote, suggest, or facilitate the sexual abuse or exploitation of a minor.

This includes content that normalizes, encourages, or trivializes such abuse, even if it does not depict a real child, and whether or not the material is intended for sexual gratification. CSAM also encompasses grooming material, manuals, or narratives that imply, advocate for, or instruct on sexual interaction with minors.

• Sexual Exploitation of Children: The use of a child for sexual purposes in exchange for money, goods, services, or other forms of compensation or influence.
  
• Grooming: Any act by which an adult builds trust with a minor (online or offline) to facilitate sexual abuse or exploitation.
  
• CSAM-Adjacent Content: Content that may not be illegal in all jurisdictions but depicts, imitates, or suggests the involvement of minors in sexual contexts. This includes, but is not limited to, cartoons, illustrations, or depictions of adult models who clearly appear to be underage, regardless of their actual age.

3. Policy Applicability and Coverage

This policy applies to all:

• Users, publishers, advertisers, and any third parties using or accessing the TrafficStars platform and/or services;
• Employees, contractors, consultants, agents, representatives, and any individuals or entities working for, on behalf of, or in connection with TrafficStars, whether directly or indirectly;
• Digital content submitted to, hosted on, or served via our platform, including but not limited to ad creatives, banners, videos, landing pages, URLs, metadata, and messaging;
• Integrated third-party systems, APIs, programmatic exchanges, demand- and supply-side partners, and any technological infrastructure interacting with or facilitating access to our platform.

4. Legal Boundaries and Applicability

TrafficStars enforces a strict zero-tolerance stance toward any content or activity involving or suggesting the sexual exploitation of children. This includes, but is not limited to:

• Visual content involving minors in sexual acts or contexts;
• AI-generated, illustrated, animated, or deepfake material that depicts or implies child exploitation;
• Written or textual content—titles, tags, descriptions, usernames, comments, chat messages, or other platform fields—that promotes or references child sexual abuse, exploitation, or sexualization;
• The use of language in ways that suggest underage sexual involvement.

TrafficStars functions exclusively as a technology facilitator: we connect advertisers with publishers through a programmatic self-serve ad network and real-time bidding (RTB) ad exchange. We do not host, control, or moderate the final content that appears on publisher websites.

As such:

• TrafficStars is not liable for the content found on third-party publisher websites where advertising placements occur.
• Advertisers are solely responsible for ensuring their creatives and destination URLs (landing pages) comply with all relevant laws and our content policies.
• Publishers are responsible for the legality and appropriateness of the content on their websites and must prevent the publication or monetization of CSAM or CSAM-adjacent content.

Despite these limitations, TrafficStars takes proactive measures to detect and prevent any illegal or abusive material from being uploaded to or distributed through our systems.

We proactively deter attempts to search for or distribute CSAM. All suspected or confirmed cases of CSAM are removed immediately and reported to the appropriate authorities.

5. Global and Local Legal Compliance Framework

This Policy is designed to comply with:

• The Prevention and Combating of Sexual Abuse, Sexual Exploitation of Children and Depiction of Child Sexual Abuse Material (Amendment) Law of 2025 (Republic of Cyprus)
• EU Directive 2011/93/EU on combating the sexual abuse and sexual exploitation of children and child pornography
• UN Convention on the Rights of the Child, including the Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography
• INHOPE and IWF operational standards
• Applicable laws in the jurisdictions where our users, servers, and partners operate

6. Detection, Prevention, and Moderation

6.1. Content Monitoring

• Screening and Monitoring:
  All content submitted to the platform is subject to screening by our dedicated Compliance Team. This team is specifically trained to identify visual, textual, and metadata-based indicators associated with child sexual abuse material (CSAM), as well as other high-risk or prohibited content categories, including but not limited to simulated abuse, grooming-related material, or depictions of individuals who appear to be minors in sexualized contexts. Screening processes include the use of both automated tools and human oversight to ensure comprehensive detection and risk assessment.
  
• Manual Review of High-Risk Material:
  Content flagged by automated systems, user reports, or internal detection mechanisms is escalated for manual review by senior moderators. These moderators are responsible to identify exploitative, deceptive, or illegal materials, with a focus on recognizing nuanced indicators of CSAM, grooming behavior, and other forms of child sexual exploitation. Each case is assessed in accordance with applicable legal frameworks and internal escalation protocols.
  
• Collaboration with Authorities:
  Where required by law or in cases involving confirmed or suspected CSAM, we immediately escalate the matter to the relevant law enforcement agencies and child protection authorities, in accordance with our legal obligations and established reporting protocols.

6.2. Moderator Training

• All content moderation staff receive regular training to review, identify, and manage potential Child Sexual Abuse Material (CSAM), in accordance with internationally recognized protocols.
• Our Compliance and Moderation teams receive continuous training to stay aligned with evolving legal standards, technological developments, and emerging trends in online exploitation tactics. We also routinely update our detection methodologies to adapt to new threat vectors.

6.3. Advertiser & Publisher Screening

• All advertisers and publishers are subject to verification and compliance checks to ensure alignment with our platform’s policies and applicable legal requirements.
• High-risk accounts are subject to a thorough manual review before approval and may be suspended pending investigation.

7. Prohibited Content

The following are explicitly and unconditionally prohibited on our platform:

• Any visual, audio, textual, or multimedia content—regardless of format or origin—that depicts, describes, or simulates sexual acts involving a minor, including but not limited to real, fictional, illustrated, animated, or AI-generated material.
• Any material, in any form, that depicts a person who appears to be a child engaging in, or shown in a context suggestive of, a real or simulated act of a sexual nature, including depictions of the genital organs of such individuals.
• Realistic images, reproductions, or representations of children—or persons presented as children—depicted in any sexual context, including content that sexualizes, fetishizes, or eroticizes children.
• AI-generated or illustrated content, deepfakes, avatars, or virtual models that represent or resemble minors in any sexual manner or context.
• Any material intended to instruct, encourage, guide, or provide information on how to engage in the sexual abuse, exploitation, or grooming of minors, including text, images, videos, audio, or metadata.
• Metadata, tags, search terms, or code intended to discover or disguise CSAM or similar material, or to facilitate its circulation within or outside the platform.
• Any content involving adults impersonating as minors for the purpose of erotic or pornographic presentation.
• External links, embedded content, or references to third-party domains known to host, promote, or distribute CSAM or related illegal material.
• Any attempt to evade, bypass, or manipulate TrafficStars’ content moderation systems, filters, or compliance protocols in order to upload, distribute, or conceal prohibited material.
• Any conduct or material—whether direct or indirect, overt or implied—that contributes to the normalization, trivialization, or facilitation of the sexual abuse or exploitation of minors.

If any CSAM-related content or activity is identified, TrafficStars reserves the right to initiate legal proceedings—civil, criminal (including private criminal complaints where applicable), or both—against any individual or entity found to be in violation of this policy. This is in addition to reporting such violations to the relevant authorities and taking internal enforcement actions, including account suspension or termination.

8. Reporting, Escalation, and Cooperation

Any content uploaded to the TrafficStars platform, or any actions carried out through our systems, that are identified as illegal or as attempts to engage in illicit activity will be addressed through the following procedures:

• The offending content or activity will be promptly removed from the platform.
• An internal investigation will be conducted to determine the scope and severity of the violation.
• The incident will be reported to the appropriate public authorities, in compliance with applicable legal obligations.
• The associated account may be suspended or permanently terminated, depending on the nature and seriousness of the violation.

TrafficStars reserves the right to suspend or terminate any account, with or without prior notice, upon suspicion, detection, or indication of activity related to Child Sexual Abuse Material (CSAM), whether directly or indirectly. In such cases, any remaining funds in the account may be withheld, refunded, or forfeited at TrafficStars’ sole discretion, subject to applicable laws, reporting obligations, and internal compliance assessments.

TrafficStars is committed to taking all necessary actions to protect its platform and users, and to ensuring full compliance with all relevant laws and regulations.

8.1. User Reporting Tools

A secure and anonymous reporting mechanism is available to all users for reporting suspected CSAM or violations of platform policies.

8.2. Internal Response Process

• All reports are reviewed by trained compliance staff within 48 hours of submission.
• Any confirmed instance of CSAM is immediately removed.
• All related evidence and metadata—including IP addresses, timestamps, and logs—are preserved under chain-of-custody protocols for use by law enforcement authorities.

8.3. Mandatory Reporting

TrafficStars reports confirmed CSAM incidents to the following authorities:

• Cyprus Police Cyber Crime Division
• Relevant international authorities, depending on the origin of the content and the user’s location

8.4. Law Enforcement Collaboration

TrafficStars maintains a dedicated Law Enforcement Contact Point to ensure effective and prompt cooperation with official investigations. We fully comply with:

• European Investigation Orders (EIOs)
• Mutual Legal Assistance Treaties (MLATs)

Upon receiving valid and verified requests from competent authorities, TrafficStars will take appropriate action, including freezing accounts, preserving data, and disclosing information—always in accordance with strict legal and privacy protocols to maintain data integrity and ensure lawful handling.

9. Law Enforcement Collaboration

• TrafficStars maintains a dedicated Law Enforcement Contact Point to ensure effective cooperation with competent authorities in the context of criminal investigations and legal proceedings.
• TrafficStars complies with all applicable legal instruments, including but not limited to European Investigation Orders (EIOs) and Mutual Legal Assistance Treaties (MLATs).
• Upon receipt of a valid and lawful request from verified authorities, TrafficStars will take all necessary measures, which may include freezing relevant user accounts and preserving associated data.
• All disclosures of user information are carried out strictly in accordance with applicable laws and legal protocols, ensuring the preservation of data integrity and full compliance with data protection and privacy regulations.

10. Age Verification

All advertisers are strictly responsible for ensuring that any content they upload to the TrafficStars platform complies with all applicable laws and regulations, particularly those related to the protection of minors. Advertisers must ensure that all individuals depicted in their creatives are adults and have given their informed consent for the use of their image and likeness. Under no circumstances may content involving minors, or content that suggests or implies the involvement of minors, be uploaded, promoted, or distributed through the platform. Failure to comply with these requirements may result in content rejection or account suspension.

TrafficStars may take appropriate action, including content removal or account termination, in cases where compliance is not maintained, in line with our efforts to adhere to legal and regulatory standards.

All services provided by TrafficStars are exclusively available to individuals who are 18 years of age or older. TrafficStars conducts periodic checks to verify that all users are at least 18 years of age, and reserves the right to request documentation to confirm compliance with this age requirement

11. Data Retention and Privacy

• CSAM-related logs, content, and account information are retained for 12 months, or longer if required by law enforcement.
• Data is stored securely using end-to-end encryption and role-based access controls.
• TrafficStars fully complies with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

12. Partner and Technology Compliance

• All third-party ad servers, RTB partners, and exchanges integrated with TrafficStars must adhere to this policy.
• Third-party services are reviewed for CSAM detection protocols.
• Partners failing to meet compliance standards are terminated and blacklisted.

13. Violations and Penalties

Any violation of this policy will result in immediate and decisive action, which may include one or more of the following measures:

• Immediate removal of the offending content from the platform;
• Permanent termination of the associated user account;
• Reporting of the incident to the appropriate law enforcement or regulatory authorities;
• Exposure to potential civil and/or criminal liability under applicable laws;
• Permanent prohibition of all related IP addresses, devices, and payment methods from accessing the TrafficStars platform.

14. Oversight and Policy Review

• The TrafficStars Compliance Department oversees the implementation and effectiveness of this policy.
• Internal audits are conducted at least annually.
• This policy is reviewed bi-annually or when prompted by changes in legislation or global enforcement standards.

15. Contact Information

To report suspected child exploitation or CSAM-related content, please contact us through the following channel:

• Email: legal@trafficstars.com 

16. Final Disclaimer

This Policy is not exhaustive and does not supersede the law. Where applicable laws impose stricter standards than this policy, the stricter standard shall apply. TrafficStars reserves the right to cooperate fully with legal and law enforcement authorities without prior notice.