Child Safety Policy

Last updated: 1 September 2026 · Effective: 1 September 2026 · Version 1.0

This Child Safety Policy explains the rules and measures Opinyn applies to protect children and young users from sexual exploitation, abuse, grooming, harassment, dangerous content and other forms of harm.

This Policy forms part of the Opinyn Terms of Use and Community Guidelines.

The Service is operated by:

Jan Nik Jesenovec – Manumed s.p.

Kokošnje 13

1233 Dob

Slovenia

Email: info@opinyn.com

Zero-tolerance principle

Opinyn has zero tolerance for:

• child sexual abuse material;
• sexual exploitation of children;
• grooming;
• sexual solicitation of minors;
• sextortion involving minors;
• trafficking or commercial exploitation of children;
• sexualisation of minors;
• content that facilitates child abuse;
• serious endangerment of children.

Such content or conduct may result in immediate content restriction, evidence preservation, permanent account termination and referral to competent authorities or authorised child-protection organisations where required or permitted by law.

Definitions

For this Policy:

“Child” or “minor” means any person under 18 years of age, regardless of the minimum age required to create an Opinyn account.

“Child sexual abuse material” or “CSAM” means any image, video, audio, text, digitally created material or other content that depicts, describes, facilitates or promotes the sexual abuse or sexual exploitation of a child, as defined by applicable law.

“Grooming” means conduct intended to gain a child’s trust or access to a child for sexual abuse, exploitation or another seriously harmful purpose.

“Sexual exploitation” includes using, coercing, manipulating, threatening, trafficking or profiting from a child for sexual purposes.

Minimum age

Users must be at least 16 years old to independently create and operate an Opinyn account.

If a higher minimum age or parental-authorisation requirement applies in the user’s country, that higher requirement applies.

By creating an account, the user confirms that:

• they meet the applicable minimum age;
• their age information is accurate;
• any legally required parental or guardian authorisation has been obtained.

Opinyn may request reasonable age or parental-authorisation verification where necessary for legal compliance or user safety.

Opinyn may restrict or delete an account where it reasonably believes that:

• the user is below the permitted age;
• required authorisation has not been obtained;
• false age information was provided;
• the account creates an unacceptable child-safety risk.

Prohibited child sexual abuse material

Users must not create, upload, publish, request, possess through the Service, exchange, link to, distribute, promote or facilitate access to CSAM.

This prohibition includes:

• photographs or videos depicting sexual abuse of a child;
• sexualised images of children;
• nude or partially nude images of children presented for sexual purposes;
• content showing a child engaged in sexual activity;
• content focusing sexually on a child’s intimate areas;
• secretly recorded sexual or intimate content involving a minor;
• content that offers or requests access to CSAM;
• instructions for finding, creating, hiding or distributing CSAM;
• links, codes, keywords or directions intended to provide access to CSAM;
• content celebrating, normalising or defending child sexual abuse.

This prohibition applies regardless of who created the material, where it was created or whether it has previously been shared elsewhere.

Digitally created and manipulated content

The prohibition applies to real, fictional, edited, computer-generated and AI-generated content.

Users must not create or share:

• AI-generated sexual imagery depicting or appearing to depict a minor;
• sexual deepfakes involving a minor;
• edited photographs that sexualise a child;
• animated or illustrated content depicting child sexual abuse;
• fictional content designed to facilitate, celebrate or normalise child sexual exploitation;
• attempts to age-regress an adult’s image to create sexualised child-like material;
• attempts to present a real child as an adult for sexual purposes.

The absence of a real child in the production process does not automatically make such content permissible.

Grooming and sexual solicitation

Users must not:

• sexually solicit a minor;
• ask a minor for nude or sexual images;
• send sexual content to a minor;
• ask a minor sexual questions for exploitative purposes;
• attempt to gain a minor’s trust for sexual activity;
• offer money, gifts, status or benefits in exchange for sexual interaction;
• pressure a minor to keep communication secret;
• encourage a minor to move sexual or inappropriate communication to another platform;
• arrange an in-person meeting with a minor for exploitative purposes;
• pretend to be younger to gain inappropriate access to a minor;
• threaten, blackmail or manipulate a minor for sexual content;
• use a dilemma, poll, comment or anonymous post to sexualise or target a minor.

Apparent grooming behaviour may be restricted before its ultimate purpose has been conclusively established where protective action is reasonably necessary.

Sextortion

Sextortion involving a minor is strictly prohibited.

Users must not:

• threaten to publish a minor’s intimate images;
• demand money, additional content or sexual activity from a minor;
• use fake or stolen intimate content to blackmail a minor;
• coerce a minor into continued communication;
• direct or encourage others to exploit a minor;
• knowingly assist another person engaged in sextortion.

Users affected by sextortion should stop communicating with the suspected offender, preserve relevant information where safe to do so, report the account and contact the appropriate authorities.

Non-sexual child endangerment

Users must not use Opinyn to:

• threaten serious harm against a child;
• encourage child abuse or neglect;
• expose a child’s precise location to a dangerous person;
• publish private information creating a serious risk to a child;
• encourage a child to participate in dangerous challenges;
• recruit a child for criminal activity;
• facilitate trafficking or forced labour;
• promote serious physical punishment or torture of children;
• encourage a child’s suicide, self-harm or eating disorder;
• sell, purchase or unlawfully transfer custody or control of a child;
• coordinate bullying or harassment of a minor.

Sexualisation of minors

Content does not need to depict explicit sexual activity to violate this Policy.

Prohibited sexualisation may include:

• sexual comments about a minor’s body;
• rating a minor’s sexual attractiveness;
• dilemmas asking users to sexualise or rank minors;
• sexual captions attached to images of minors;
• fetishisation of children;
• invitations for sexual comments about minors;
• repeated sexual focus on a minor;
• content designed to attract sexual attention toward a child;
• sexualised screenshots or edits of a minor.

Images and information involving minors

Users must exercise particular care when publishing content involving a minor.

Users must not publish:

• intimate or humiliating images of a minor;
• images depicting abuse or serious distress for entertainment;
• identifying information that creates a safety risk;
• school, home or precise location information where it could expose a child to harm;
• confidential health or family information without a lawful basis;
• content violating the child’s privacy or dignity;
• content published without necessary authority or permission.

Parental permission does not make exploitative, dangerous or unlawful content permissible.

Bullying and harassment of minors

Opinyn does not permit targeted bullying or harassment of minors.

Prohibited conduct includes:

• repeated degrading attacks;
• sexual harassment;
• threats;
• blackmail;
• doxxing;
• coordinated humiliation;
• encouraging others to harass a minor;
• mocking a minor’s disability, appearance, trauma or private circumstances;
• creating accounts or dilemmas to humiliate a minor;
• sharing private communications to harm a minor;
• telling a minor to die or harm themselves.

The age and vulnerability of the affected person will be considered when deciding the appropriate enforcement response.

Dangerous challenges

Users must not encourage minors to participate in activities likely to cause serious injury, death, poisoning, suffocation, burns, overdose or another grave danger.

Content must not:

• provide instructions for dangerous challenges;
• pressure minors to participate;
• shame minors for refusing;
• conceal the risk;
• celebrate serious injuries;
• encourage bypassing adult supervision.

Educational content warning against dangerous behaviour may be permitted where the warning context is clear and harmful instructions are not unnecessarily detailed.

Self-harm and suicide

Users may discuss mental health, recovery and requests for support.

Users must not:

• encourage a minor to self-harm or attempt suicide;
• provide detailed instructions;
• glorify or romanticise self-harm;
• coordinate self-harm activity;
• direct vulnerable minors toward harmful communities;
• shame or provoke a suicidal user;
• promote eating disorders or extreme starvation.

Where Opinyn becomes aware of a credible imminent threat, it may take protective steps, including restricting content and contacting competent emergency services where legally permitted.

Opinyn is not an emergency service.

Adult–minor interactions

Adults must maintain appropriate boundaries when interacting with minors.

Adults must not:

• pursue sexual or romantic interaction with minors;
• request private sexual communication;
• pressure minors to disclose private information;
• encourage secrecy from parents or guardians;
• manipulate minors using money, gifts or status;
• move inappropriate contact to another platform;
• exploit differences in age, authority or vulnerability.

Opinyn may restrict adult accounts displaying patterns of suspicious contact with minors even where no single interaction conclusively establishes abuse.

Reporting child-safety concerns

Users who reasonably suspect a child-safety violation must promptly report it through the in-app reporting function.

Select:

Child Safety

The report should identify:

• the relevant content or account;
• what happened;
• why a child may be at risk;
• whether the danger appears immediate;
• any relevant context.

Do not:

• download suspected CSAM;
• forward it to friends or ordinary support channels;
• take unnecessary copies;
• confront a suspected offender;
• publicly identify a suspected child victim;
• redistribute the material as evidence.

Use Opinyn’s reporting tool and contact competent authorities where necessary.

Immediate danger

If a child appears to be in immediate danger:

• contact the appropriate emergency services or police;
• use Opinyn’s Child Safety reporting category;
• provide the information necessary to locate and assess the threat;
• do not rely solely on an email or platform report.

Opinyn cannot guarantee immediate emergency intervention.

Opinyn’s response

When Opinyn identifies a credible child-safety concern, it may:

• immediately hide or disable access to content;
• suspend or restrict accounts;
• preserve relevant account and technical information;
• prevent further interaction;
• restrict internal access to authorised persons;
• review related content or accounts;
• prevent creation of replacement accounts;
• report the matter to competent authorities or authorised organisations;
• comply with lawful preservation and disclosure requests;
• permanently terminate accounts;
• take other reasonably necessary protective measures.

Protective measures may be taken before a full investigation is completed.

Evidence handling

Suspected CSAM and other highly sensitive child-safety evidence must be handled carefully.

Opinyn will seek to:

• limit access to specifically authorised persons;
• avoid unnecessary viewing;
• avoid unnecessary copying or downloading;
• maintain records of administrative access;
• protect the identity of potential victims;
• preserve evidence where legally required or reasonably necessary;
• securely delete information when retention is no longer required;
• avoid disclosing sensitive evidence to persons without a lawful need.

Content may be hidden from users but retained in a restricted system where evidence preservation is necessary.

Reporting to authorities

Opinyn may report suspected child sexual exploitation, abuse, grooming, trafficking or immediate danger to:

• law-enforcement authorities;
• courts;
• child-protection authorities;
• emergency services;
• legally designated reporting bodies;
• authorised child-safety organisations.

Reports will be made where required by law or where legally permitted and reasonably necessary to protect a child.

Opinyn may preserve and disclose account, content, voting, device, IP-address and communication information when lawfully required.

Confidentiality

Opinyn will seek to protect:

• the identity of a child victim;
• the identity of a good-faith reporter;
• confidential evidence;
• investigation details;
• information supplied by authorities.

Information may be disclosed where required by law or reasonably necessary for safety and enforcement.

The reported user may receive a general explanation of an enforcement decision but may not receive information that could expose a child, reporter or investigation.

False and abusive reports

Users must not knowingly submit false child-safety reports.

Child Safety reporting must not be used to:

• retaliate against another user;
• silence lawful speech;
• harass a person;
• create a false criminal accusation;
• manipulate moderation.

Opinyn may restrict users who deliberately abuse child-safety reporting.

A good-faith report will not violate this rule merely because the concern is ultimately not confirmed.

Account actions

A confirmed child-safety violation may result in:

• immediate content removal;
• loss of specific features;
• account suspension;
• permanent termination;
• prevention of replacement accounts;
• evidence preservation;
• reporting to competent authorities.

Serious sexual exploitation violations may result in permanent termination without a prior warning.

Appeals

A user may appeal an eligible child-safety enforcement decision using the method provided in the decision notice or by contacting info@opinyn.com.

An appeal does not automatically restore content or account access.

Opinyn may withhold sensitive evidence and investigation details where disclosure could:

• expose a child;
• identify a reporter;
• facilitate further abuse;
• interfere with an investigation;
• violate applicable law.

The protection of children takes priority over disclosure of unnecessary sensitive details.

Privacy of young users

Opinyn processes personal data of young users according to the Privacy Policy.

Opinyn will not use minors’ personal data or sensitive voting inferences for targeted advertising.

Young users should not publicly share:

• home or school addresses;
• telephone numbers;
• personal email addresses;
• passwords;
• identification documents;
• live or precise location;
• travel routines;
• intimate images;
• confidential health information;
• information that could enable unwanted contact.

Parents and guardians

A parent or legal guardian who believes that a minor:

• created an account without required authorisation;
• is being groomed or exploited;
• is exposed to serious danger;
• has published personal information;
• appears in harmful content;

may contact info@opinyn.com.

The request should include enough information to identify the relevant account or content.

Opinyn may request reasonable evidence of identity and parental or legal authority before disclosing information or acting on certain requests.

Verification will not be used to delay urgent protective measures.

Educational and public-interest content

Content discussing child abuse prevention, news, research, medical care, recovery or child protection may be permitted where:

• the purpose is legitimate;
• prohibited imagery is not included;
• victims are not unnecessarily identified;
• details do not facilitate abuse;
• the presentation respects the dignity and safety of children.

A claimed educational or documentary purpose does not excuse exploitative or unlawful content.

Training and internal access

Persons handling child-safety cases should receive appropriate instructions concerning:

• recognition of grooming and exploitation;
• evidence handling;
• confidentiality;
• escalation procedures;
• applicable reporting obligations;
• avoiding unnecessary exposure to harmful material;
• secure documentation.

Access should be limited according to job responsibilities.

Changes to this policy

Opinyn may update this Policy to address:

• changes in law;
• new child-safety risks;
• new Service features;
• new reporting or moderation tools;
• recommendations from competent authorities.

The latest version will be made available through the Service.

Contact

Child-safety concerns should normally be reported through the in-app reporting function by selecting “Child Safety”.

Additional reports and questions may be sent to:

Jan Nik Jesenovec – Manumed s.p.

Kokošnje 13

1233 Dob

Slovenia

Email: info@opinyn.com

For immediate danger, contact the relevant emergency services or police.