Child Safety & CSAE Policy

1. Zero-Tolerance Policy

RoadTalk strictly prohibits any content, conduct, communication, or activity that sexually abuses, exploits, or endangers a child.

Users may not use RoadTalk to:

• Sexually abuse or exploit a child.
• Groom or manipulate a child for sexual purposes.
• Sexually solicit or entice a child.
• Request, create, produce, upload, store, possess, transmit, distribute, or share CSAM.
• Request or solicit sexually explicit images, videos, or other sexual material from a minor.
• Send sexually explicit material to a minor.
• Sexualize, objectify, or portray children in a sexually exploitative manner.
• Arrange or attempt to arrange sexual contact or sexual encounters with a minor.
• Recruit, solicit, transport, or facilitate the sexual exploitation of a child.
• Facilitate or promote child sex trafficking.
• Engage in sextortion, sexual blackmail, threats, or coercion involving a minor.
• Offer money, gifts, transportation, employment, or anything of value in exchange for sexual activity or sexual material involving a minor.
• Encourage a child to conceal sexual communications, meetings, or relationships.
• Use RoadTalk to identify, target, recruit, or contact children for sexual purposes.
• Move communications with a minor to another platform for purposes of sexual exploitation or abuse.
• Attempt to circumvent RoadTalk’s age restrictions, safety systems, moderation systems, reporting mechanisms, or enforcement actions for purposes prohibited by this Policy.

These prohibitions apply regardless of whether the conduct occurs through public or private communications.

2. Child Sexual Abuse Material (CSAM)

RoadTalk strictly prohibits the creation, production, upload, possession, storage, solicitation, transmission, distribution, or sharing of CSAM.

For purposes of this Policy, CSAM generally refers to material depicting or otherwise documenting the sexual abuse or sexual exploitation of a child.

RoadTalk will take appropriate action when it obtains actual knowledge of CSAM or other reportable child sexual exploitation on its service, consistent with applicable law and this Policy.

Appropriate action may include:

• Restricting or removing access to prohibited content.
• Suspending or terminating accounts.
• Restricting access to RoadTalk features.
• Preserving relevant information as required or permitted by law.
• Reporting apparent violations to the National Center for Missing & Exploited Children (“NCMEC”) or appropriate law-enforcement authorities when required by law.
• Cooperating with lawful investigations and legal processes.

RoadTalk does not permit users to upload or redistribute suspected CSAM for the purpose of making a report.

3. Online Grooming and Enticement

RoadTalk prohibits grooming and online enticement of children for sexual purposes.

Prohibited conduct includes, but is not limited to:

• Establishing or attempting to establish a relationship with a child for sexual purposes.
• Building trust with a child as a step toward sexual exploitation.
• Introducing sexual conversations or material to a child for sexual purposes.
• Requesting sexual images or videos from a child.
• Sending sexual content to a child.
• Offering money, gifts, transportation, employment, or other benefits in exchange for sexual activity or sexual content.
• Encouraging a child to keep communications or meetings secret.
• Attempting to arrange an in-person meeting with a child for sexual purposes.
• Threatening or manipulating a child into providing sexual content.
• Moving a conversation to another platform for purposes of sexual exploitation.
• Using RoadTalk’s communication or location features to facilitate sexual exploitation of a child.

4. Sextortion and Sexual Blackmail Involving Minors

RoadTalk strictly prohibits sextortion, sexual blackmail, threats, and coercion involving minors.

Users may not:

• Threaten to publish or distribute sexual images or information involving a minor.
• Demand money, additional images, sexual acts, or anything else of value in exchange for withholding sexual content.
• Threaten, intimidate, manipulate, or coerce a minor into providing sexual material.
• Use previously obtained sexual material involving a minor to threaten, control, or exploit that minor.
• Encourage another person to participate in sextortion or sexual exploitation of a minor.

RoadTalk may take immediate enforcement action and may report apparent criminal conduct to appropriate authorities when required or permitted by applicable law.

5. Child Sex Trafficking and Commercial Sexual Exploitation

RoadTalk strictly prohibits using the service to facilitate, promote, advertise, arrange, recruit for, or participate in the sexual trafficking or commercial sexual exploitation of children.

Users may not:

• Recruit or solicit a minor for commercial sexual exploitation.
• Advertise or arrange the sexual exploitation of a minor.
• Offer or request payment or anything of value in connection with the sexual exploitation of a minor.
• Facilitate transportation or meetings for purposes of sexually exploiting a child.
• Assist, promote, or facilitate another person’s sexual exploitation or trafficking of a child.

6. Minimum Age and Age Restrictions

RoadTalk is intended for users who satisfy RoadTalk’s minimum age requirement and all applicable legal requirements.

Users must provide truthful age information when required by RoadTalk.

Users may not:

• Falsify their age to circumvent RoadTalk’s age restrictions.
• Create or maintain an account for a child in violation of RoadTalk’s age requirements.
• Help another person circumvent RoadTalk’s age restrictions.
• Use RoadTalk to facilitate prohibited sexual or exploitative contact between adults and minors.

RoadTalk may suspend or terminate an account when it reasonably believes that the account does not satisfy applicable age requirements.

Where RoadTalk’s services are not directed to children, RoadTalk will not knowingly design or market those services to children in violation of applicable law.

7. In-App Reporting

RoadTalk provides an in-app mechanism through which users can report safety concerns and suspected violations of this Policy.

Users may report suspected:

• CSAM.
• Child sexual abuse or exploitation.
• Child grooming.
• Online sexual enticement of a child.
• Sexual solicitation of a minor.
• Sextortion involving a minor.
• Child sex trafficking.
• Sexual exploitation of a minor.
• Other conduct that may place a child at risk.

Users should report concerning activity as soon as reasonably possible.

Reports should include relevant information reasonably available to the reporting user, such as:

• Username or profile information.
• The nature of the concern.
• Relevant dates or times.
• The RoadTalk feature where the conduct occurred.
• Other information that may assist RoadTalk in evaluating the report.

Users should not intentionally seek out additional illegal material to support a report.

8. Do Not Download, Save, Copy, or Redistribute Suspected CSAM

Users must not intentionally download, save, copy, forward, repost, transmit, or redistribute suspected CSAM.

If a user encounters suspected CSAM or suspected sexual exploitation of a child, the user should report the account or conduct through RoadTalk’s reporting mechanism.

Users should not:

• Download additional illegal material.
• Ask another person to send additional illegal material.
• Redistribute suspected CSAM.
• Publish suspected CSAM publicly.
• Confront or threaten suspected offenders.
• Attempt to conduct their own investigation.

RoadTalk may request information necessary to evaluate a report, but users should not provide illegal material beyond what is legally necessary and permitted.

9. Handling of Reports

RoadTalk will maintain procedures for receiving, reviewing, and responding to reports involving CSAE and CSAM.

RoadTalk may evaluate reports using available information, automated safety systems, human review, account information, communications, and other appropriate safety measures, subject to applicable law and RoadTalk’s Privacy Policy.

A report does not by itself establish that a violation occurred.

RoadTalk may take immediate protective or enforcement action when circumstances warrant, including while a report is being reviewed.

RoadTalk may prioritize reports involving an immediate risk to a child.

10. Action Upon Obtaining Actual Knowledge of CSAM

When RoadTalk obtains actual knowledge of CSAM or other reportable child sexual exploitation covered by applicable law, RoadTalk will take appropriate action consistent with its legal obligations.

Such action may include:

• Restricting access to the material.
• Removing or disabling access to the material where legally appropriate.
• Taking action against associated accounts.
• Preserving relevant information as required or permitted by law.
• Making required reports to NCMEC through the CyberTipline.
• Cooperating with appropriate law-enforcement authorities.

RoadTalk will not knowingly permit CSAM to remain available through its service after obtaining actual knowledge of such material, subject to applicable legal requirements and any necessary preservation obligations.

11. U.S. Federal Reporting Requirements

RoadTalk is committed to complying with applicable United States federal child-safety laws.

To the extent RoadTalk is subject to the reporting requirements applicable to providers under 18 U.S.C. § 2258A, RoadTalk will comply with those requirements.

Where the law requires reporting after RoadTalk obtains actual knowledge of specified facts or circumstances involving apparent child sexual exploitation, RoadTalk will submit the required report to NCMEC’s CyberTipline as soon as reasonably possible and within any deadline required by applicable law.

This may include apparent violations involving:

• CSAM.
• Online enticement of a child.
• Child sex trafficking.
• Other conduct specifically covered by applicable federal reporting requirements.

RoadTalk may also report other suspected child abuse, exploitation, trafficking, or criminal activity to appropriate law-enforcement authorities or other authorized organizations when required or permitted by law.

Nothing in this Policy limits RoadTalk’s legal reporting obligations.

12. NCMEC CyberTipline

RoadTalk will maintain procedures for making reports to the National Center for Missing & Exploited Children (“NCMEC”) through the CyberTipline when required by applicable law.

Reports may contain information required by law, which may include information concerning:

• The reported content or conduct.
• The user account associated with the report.
• Available identifying information.
• Relevant communications or other information.
• Information concerning the location or jurisdiction of the suspected activity when available.
• Other information required by applicable law.

RoadTalk will handle such information in accordance with applicable law and its Privacy Policy.

NCMEC’s CyberTipline serves as a reporting system for suspected online child sexual exploitation and assists law enforcement in responding to such reports. (NCMEC)

13. Preservation of Information

Where RoadTalk submits a report to the CyberTipline or is otherwise required by applicable law to preserve information, RoadTalk will preserve relevant information in accordance with applicable legal requirements.

Under applicable U.S. federal law, a completed CyberTipline report may trigger statutory preservation requirements, including preservation of the contents provided in the report and reasonably accessible related visual depictions, data, or digital files that may provide context or additional information.

RoadTalk will maintain preserved materials securely and limit access to personnel who need access to perform legally authorized or required functions.

RoadTalk may preserve information for longer periods when required by law, legal process, or where otherwise legally permitted and reasonably necessary for child-safety or law-enforcement purposes.

The applicable federal preservation period has been amended to one year following a completed CyberTipline report. (Legal Information Institute)

14. Disclosure to Law Enforcement

RoadTalk may disclose information relating to CSAE investigations to appropriate authorities when required or permitted by applicable law.

RoadTalk may respond to valid:

• Subpoenas.
• Court orders.
• Warrants.
• Other legally enforceable requests.
• Emergency requests where permitted by law.

RoadTalk may also cooperate with federal, state, local, tribal, or appropriate foreign law-enforcement authorities in accordance with applicable law.

Nothing in this Policy requires RoadTalk to disclose information beyond what is legally required or permitted.

15. Child Safety Point of Contact

RoadTalk maintains a designated Child Safety Point of Contact who is responsible for receiving and responding to child-safety matters and, where appropriate, communicating with platform providers, authorities, and other authorized parties.

Child Safety Contact: RoadTalk Safety Team

Email: info@road-talk.com

The designated contact must be capable of addressing RoadTalk’s CSAE prevention, reporting, review, and enforcement procedures.

16. Safety and Moderation Measures

RoadTalk may use reasonable safety and moderation measures designed to prevent, identify, investigate, and respond to CSAE and other prohibited conduct.

Depending on the features of the RoadTalk service, these measures may include:

• User reporting.
• Content moderation.
• Account review.
• Automated detection or classification technologies.
• Human review.
• Account restrictions.
• Feature restrictions.
• Blocking or disabling communications.
• Suspension or termination.
• Preservation of relevant information.
• Reporting to appropriate authorities.

RoadTalk may modify or improve its safety measures as technology, threats, laws, regulations, and industry practices evolve.

No online service can guarantee that every violation will be detected or prevented.

17. Enforcement

Violations of this Policy may result in immediate enforcement action.

Depending on the circumstances, RoadTalk may:

• Remove or restrict content.
• Disable communications.
• Restrict specific features.
• Suspend an account.
• Permanently terminate an account.
• Prevent the creation of replacement accounts.
• Preserve relevant information.
• Report apparent violations to NCMEC or law enforcement when required or appropriate.
• Take other measures reasonably necessary to protect children and users.

RoadTalk may take action without prior notice when necessary to protect users, children, or the integrity of an investigation.

RoadTalk may consider the seriousness, credibility, frequency, circumstances, and potential harm associated with a reported violation when determining appropriate action.

18. Circumvention of Safety Measures

Users may not circumvent, disable, interfere with, or attempt to defeat RoadTalk’s child-safety or moderation systems.

Prohibited conduct includes:

• Creating replacement accounts after termination.
• Using false information to evade enforcement.
• Manipulating reporting systems.
• Circumventing age restrictions.
• Using technical methods to bypass safety controls.
• Continuing prohibited communications through another RoadTalk account after enforcement action.

Attempts to circumvent RoadTalk’s child-safety measures may result in additional enforcement action.

19. Privacy and Child-Safety Investigations

RoadTalk respects user privacy while recognizing that applicable law may require the processing, preservation, or disclosure of information for child-safety and law-enforcement purposes.

Information relating to a child-safety report may be processed or retained when reasonably necessary to:

• Investigate a reported violation.
• Protect users or children.
• Comply with legal obligations.
• Submit legally required reports.
• Preserve evidence or information as required by law.
• Respond to lawful requests from authorities.

RoadTalk’s general collection, use, retention, and disclosure of personal information are described in the RoadTalk Privacy Policy.

RoadTalk will not intentionally publicly expose the identity of a suspected victim or reporting user except where disclosure is required or permitted by law.

20. Good-Faith Reporting

RoadTalk encourages users to make truthful and good-faith reports concerning suspected child exploitation or abuse.

Users should provide accurate information to the best of their knowledge.

Knowingly submitting false information, fabricating evidence, maliciously targeting another user, or abusing RoadTalk’s reporting mechanisms may violate the RoadTalk Terms of Service and may result in enforcement action.

This section does not prohibit good-faith reports made by users who reasonably believe a child may be at risk.

21. Users Should Not Take Enforcement Into Their Own Hands

RoadTalk encourages users to report suspected CSAE rather than attempting to investigate or confront suspected offenders.

Users should not:

• Threaten suspected offenders.
• Arrange meetings with suspected offenders.
• Publish personal information about suspected offenders.
• Attempt to obtain additional illegal material.
• Distribute suspected CSAM.
• Impersonate law enforcement.
• Interfere with an investigation.

Reports should be made through RoadTalk’s reporting mechanisms and, where appropriate, to law enforcement or other authorized child-safety organizations.

22. Emergency Situations

If a user believes a child is in immediate physical danger, the user should contact appropriate emergency or law-enforcement authorities immediately.

RoadTalk’s reporting system is not intended to replace emergency services.

RoadTalk may take emergency protective measures and may cooperate with appropriate authorities to the extent permitted or required by applicable law.

23. Compliance With Applicable Laws

RoadTalk intends to comply with applicable federal, state, and local laws relating to child safety, child sexual exploitation, online services, privacy, reporting obligations, and the protection of minors.

Because laws may vary by jurisdiction and may change over time, RoadTalk may implement additional procedures or restrictions when necessary to comply with applicable legal requirements.

Nothing in this Policy limits RoadTalk’s legal obligations.

24. Relationship to the Terms of Service

A violation of this Child Safety & CSAE Policy may also constitute a violation of the RoadTalk Terms of Service.

If a conflict exists between this Policy and a mandatory legal requirement, the applicable legal requirement will control.

RoadTalk reserves the right to take any action permitted by its Terms of Service and applicable law to protect children, users, and the RoadTalk community.

25. Policy Updates

RoadTalk may update this Policy periodically to reflect:

• Changes in applicable law.
• Changes in regulatory requirements.
• Changes in platform requirements.
• Changes in RoadTalk’s features or services.
• Changes in child-safety threats.
• Improvements to RoadTalk’s safety practices.

When material changes are made, RoadTalk may update the “Last Updated” date and publish the revised Policy through the RoadTalk website or application.

26. Contact RoadTalk

For questions, concerns, or reports relating to child safety or CSAE:

RoadTalk

Child Safety Contact: RoadTalk Safety Team

Child Safety Email: info@road-talk.com

Website: https://www.road-talk.com

RoadTalk Child Safety Commitment

RoadTalk has zero tolerance for child sexual abuse and exploitation.

RoadTalk is committed to maintaining reasonable measures to prevent, identify, respond to, and report child-safety violations and to cooperating with appropriate authorities as required by applicable law.

Protecting children is a shared responsibility. Users are encouraged to report suspected child sexual exploitation promptly through RoadTalk’s in-app reporting mechanism.