Child Safety & CSAE Policy

Winter (operated by Winter App Inc., package name com.app.screentime) maintains an absolute Zero-Tolerance Policy against Child Sexual Abuse Material (CSAM) and Child Sexual Abuse and Exploitation (CSAE).

1. Strict 18+ Age Restriction & Age Verification

Winter is an adult-only dating and connection platform designed exclusively for individuals who are 18 years of age or older (or the age of legal majority in their jurisdiction).

• No Minors Permitted: Individuals under the age of 18 are legally prohibited from creating an account, browsing profiles, exchanging messages, or participating in WebRTC voice and video calls.
• Mandatory Date of Birth Verification: During user registration, all applicants must declare their accurate date of birth. Accounts indicating an age under 18 are rejected immediately at onboarding.
• Biometric & Live Selfie Verification: We deploy liveness detection and automated facial age estimation technologies during onboarding. Any profile suspected of being operated by a minor or misrepresenting adult age is blocked and flagged for human safety review.

2. Prohibited Content & Conduct (CSAE/CSAM)

In accordance with Google Play Developer Policy and international child protection laws, Winter strictly bans:

• Child Sexual Abuse Material (CSAM): Any visual, photographic, digital, video, audio, or computer-generated depiction of a minor engaged in sexually explicit or suggestive conduct.
• Child Sexual Exploitation and Abuse (CSAE): Any act of grooming, sexual extortion (sextortion), sexual coercion, propositioning, or soliciting sexual activity with or involving a minor.
• Sexualization of Minors: Sharing, uploading, transmitting, or requesting images, texts, voice notes, or videos that sexualize minors or suggest underage sexual behavior.
• Child Grooming: Attempting to build an emotional connection with a minor to facilitate sexual contact, exploitation, or abuse.
• Trafficking: Any commercial sexual exploitation, trafficking, or prostitution involving children or youths.

3. Preventative Safeguards & Proactive Detection

To prevent the proliferation of CSAE and protect minors, Winter implements layered technical, algorithmic, and human safeguards:

• Automated Media Screening: All photos uploaded to profiles or shared across chats are screened against known digital hash databases (such as PhotoDNA / PDQ hashing) and real-time computer vision classifiers for explicit material.
• Real-Time Text Safety Filters: Natural language processing (NLP) models monitor message patterns, flagged keywords, and solicitation attempts related to underage interactions.
• Restricted Peer-to-Peer Calling: WebRTC voice and video calls can only occur between mutually matched, verified adult users. Unsolicited calling or streaming to unverified accounts is technically restricted.
• 24/7 Safety Review Team: Dedicated human safety specialists review flagged interactions, user reports, and automated safety triggers around the clock.

4. User Reporting Mechanisms (In-App & Web)

Every user on Winter has access to clear, immediate reporting tools built directly into the interface:

A. In-App Reporting

1. Profile Reporting: Tap the three-dot menu (⋮) on any user profile → Select Report User → Choose the category "Underage User" or "Child Safety / Inappropriate Content" → Submit.
2. Chat Reporting: Inside any direct conversation, long-press the offending message or tap the header menu → Select Report Message / User → Choose "Child Exploitation / Underage".
3. Live Call Reporting: During or immediately following a WebRTC voice/video call, tap the Report button to immediately alert our emergency trust and safety queue.

B. Web & Direct Emergency Reporting

Reports can also be filed directly via our safety response email:

5. Immediate Enforcement & Account Termination

Upon receiving any report or automated alert involving CSAE or CSAM:

• Immediate Account Suspension: The reported account is locked instantly to prevent further communication or activity.
• Permanent Ban: Upon confirmation, the account is permanently terminated. Associated device IDs, phone numbers, email addresses, and payment instruments are permanently blocklisted.
• Content Eradication: All offending content is permanently purged from our public feeds and communications servers after evidentiary retention.
• Evidence Preservation: Server logs, timestamps, IP addresses, transaction records, and communication metadata are securely archived under cryptographic tamper-proof protections for law enforcement submittal.

6. Mandatory Law Enforcement & NCMEC Reporting

Winter fulfills all legal obligations under 18 U.S.C. § 2258A and applicable international statutes regarding child safety:

• NCMEC CyberTipline Reports: We file formal, expedited reports with the National Center for Missing & Exploited Children (NCMEC) detailing the offender's profile details, IP addresses, timestamps, and preserved digital material.
• Full Law Enforcement Cooperation: We proactively cooperate with state, federal, and international law enforcement agencies (including the FBI, Homeland Security Investigations, and INTERPOL) to facilitate apprehension and prosecution of offenders.

7. Emergency Helplines & Support Resources

If you or someone you know has been affected by child exploitation, abuse, or online extortion, the following free, confidential resources are available 24/7:

8. Designated Child Safety Contact

For legal inquiries, regulatory questions, or partner communications regarding child safety and our CSAE policies: