INTRODUCTION
VELARIS INTERNATIONAL INC. (“Company”) maintains a zero-tolerance policy towards any content related to the sexualization, sexual exploitation, or threat to children (material concerning sexual abuse of children or CSAM) on our Website https://lollihub.com. This specifically includes media, text, videos, illustrations, or computer-generated images that are illegal, obscene, offensive, harmful, or inappropriate.
We strive to ensure that our Website is not used to share, view, or consume any such content and will promptly remove and report any violations we detect or become aware of. For the purpose of this policy, a child is defined as any individual under the age of eighteen (18) years or the age of majority in the applicable jurisdiction, whichever is higher.
CSAM AND PROHIBITED CONTENT
Child Exploitation
It is strictly prohibited to upload, distribute, or engage with any content that includes:
- Child pornography or sexual images of persons who appear to be minors (regardless of actual age)
- Any content depicting someone under 18 through scripting, makeup, behavior, costume, setting, or props
- Animated or cartoon sexual images involving minors
- Materials that promote the sexualization of children in any way
Distribution, Acquisition, and Possession of Child Pornography
Distribution, broadcasting, uploading, or providing access on the Website to any child pornographic content is strictly forbidden. Child pornography is defined as any pornographic content relating to:
- Sexual acts performed by a person under 18 years old
- Images of a child under 18 in a state of undress in a sexually provocative pose
- Sexually provocative images of a child's genitals or buttocks
Any attempt to obtain, acquire, or possess child pornography depicting real or realistic acts for the purpose of providing it to others is prohibited.
REPORTING MECHANISMS
How to Report CSAM
If any user discovers CSAM on our Website, they should immediately report it using one of the following methods:
Emergency CSAM reports:
- Email: csam-report@lollihub.com
- Website form: https://lollihub.com/report-csam
- General support: support@lollihub.com (marked URGENT - CSAM)
Anonymity and Confidentiality:
- Reports may be submitted anonymously
- All reports will be kept strictly confidential
- Reporters’ personal information is protected according to our Privacy Policy
Response Timeframes
- Immediate response: All CSAM reports are treated as critical and addressed immediately
- Content removal: Within 1 hour of violation confirmation
- Law enforcement notification: Within 24 hours of detection
- Account suspension: Immediate upon violation confirmation
Escalation Procedure
- Initial review: Moderation team (within 30 minutes)
- Verification: Senior moderator or management (within 1 hour)
- Actions: Removal, suspension, law enforcement notification (immediate)
- Documentation: Preservation of evidence for investigation
ENFORCEMENT MEASURES
Technological Solutions
We have strict policies, operational mechanisms, and technologies to combat CSAM and take swift action against it. When we detect or learn of actual or potential CSAM on the Website, we remove and investigate the content and report any materials identified as CSAM.
Automated detection tools:
- CSAI Match (YouTube) — a tool that helps identify known videos containing scenes of child sexual abuse
- PhotoDNA (Microsoft) — a tool that helps detect and remove known images of child sexual abuse
- Safer (Thorn) — a comprehensive tool for detecting CSAM content that protects platforms from abusive materials
- NCMEC Hash Sharing — a database of known CSAM hashes from NCMEC, including hashes submitted by content originators
Human Moderation
Combined with technical tools, our team of trained moderators:
- Conducts regular content reviews
- Investigates all user reports
- Makes final decisions on disputed cases
- Receives specialized training to identify CSAM
CONSEQUENCES OF VIOLATIONS
Immediate Sanctions
Any agency, model, or subscriber found uploading, distributing, or possessing CSAM will be:
- Immediately removed from the Website
- Permanently banned without possibility of reinstatement
- Reported to law enforcement for investigation
- Deprived of all account funds without refund
Cooperation with Law Enforcement
We will:
- Report all apparent CSAM cases to NCMEC and relevant federal agencies
- Fully cooperate with law enforcement investigations
- Provide any information that may assist in prosecuting offenders
- Preserve evidence in accordance with legal requirements
Data Retention for Investigations
- Offender data: Retained until investigations are complete
- CSAM evidence: Transferred to authorities and removed from our servers
- Activity logs: Retained as required by law enforcement
LEGAL COMPLIANCE AND LIMITATIONS
Legal Compliance
VELARIS INTERNATIONAL INC. operates in compliance with:
- U.S. federal child protection laws
- FOSTA-SESTA requirements
- International conventions on children’s rights
- NCMEC reporting requirements
System Limitations
Despite our best efforts, no system is perfect, and we cannot guarantee all CSAM will be detected and removed before upload. We rely on:
- The vigilance of our users
- Continuous improvement of technologies
- Collaboration with industry partners
- Moderator training
Policy Updates
We reserve the right to update this policy as needed to adapt to:
- Emerging threats
- New detection technologies
- Changes in legislation
- Industry best practices
SUPPORT AND EDUCATION RESOURCES
Company Commitments
VELARIS INTERNATIONAL INC. is committed to playing an active role in combating child sexual exploitation and abuse. We will continue to invest in and improve our:
- Protection policies
- Detection technologies
- Partnerships with law enforcement
- Staff training programs
Educational Resources
To raise user awareness, we provide:
- Information on how to recognize CSAM
- Digital safety resources for parents
- Links to victim support organizations
- Prevention materials
Partnerships
We actively collaborate with:
- NCMEC (National Center for Missing & Exploited Children)
- Internet Watch Foundation
- Thorn (Digital Defenders of Children)
- U.S. law enforcement agencies and international organizations
CONTACT INFORMATION
CSAM Reports
- Emergency email: csam-report@lollihub.com
- Website form: https://lollihub.com/report-csam
- Support phone: [to be added]
General Policy Inquiries
- Email: child-safety@lollihub.com
- General support: support@lollihub.com
Law Enforcement Requests
- Email: legal@lollihub.com