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CSAE Declaration –
Policy for the protection of Children

1. Purpose and Commitment

Jelper Club ("we", "our", "the Platform") maintains a zero‑tolerance stance toward Child Sexual Abuse and Exploitation (CSAE).


This policy sets out the principles, processes, and controls that protect minors (anyone under 18 years of age) who may interact with, or be depicted on, the Platform, in compliance with:

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  • The United Nations Convention on the Rights of the Child (UNCRC)

  • Japanese Act on Regulation and Punishment of Acts Relating to Child Prostitution and Child Pornography, and the Protection of Children (1999)

  • Relevant laws in jurisdictions where we operate (e.g., U.S. PROTECT Act, EU CSAM Directive)

  • App Store / Play Store developer policies and industry best‑practice (e.g., Technology Coalition’s Project Protect).

 

2. Scope

This policy applies to:

  • All users (students and corporate)

  • All staff, contractors, and volunteers

  • All content & data hosted, transmitted, or otherwise processed by Jelper Club products, websites, APIs, social‑media channels, and offline events.
     

3. Definitions

  • CSAE – Any material that depicts or facilitates sexual activity involving a minor, including grooming, sexualised comments, or requests for sexual imagery.

  • Known CSAM – Images/videos already in global hash databases (e.g., NCMEC, INTERPOL).

  • Suspected CSAM – Material that is not yet classified but is likely illegal or abusive.

  • Grooming – A course of behaviour designed to establish trust with a minor with the goal of sexual exploitation.
     

4. Core Principles

  1. Zero Tolerance – Any CSAE content or behaviour results in immediate removal and permanent account ban.

  2. ‘Safety by Design’ – Child‑protection controls are embedded during product design, not retro‑fitted.

  3. Proactive Detection – We combine industry hash‑matching, AI classification, and human moderation.

  4. Rapid Reporting – All confirmed content is reported to the National Police Agency (Japan) and NCMEC (U.S.) within 24 hours.

  5. Victim‑Centric – Where possible we cooperate with law‑enforcement and NGOs to support victims and preserve evidence.

 

5. Reporting & Escalation

  • User reporting – Prominent "Report" button on profiles, messages, uploads; reports auto‑escalate to Tier‑1 moderators.

  • Internal escalation – CSAE→Tier‑3 specialist; legal & law‑enforcement liaison within 30 minutes.

  • External – NCMEC CyberTipline (U.S.) or relevant local hotline; preservation of evidence for at least 90 days.
     

6. Data Privacy & Storage

  • CSAE imagery is never stored beyond legal retention requirements; instead we retain hash values only.

  • Access is restricted (Role‑Based Access Control, logged, 4‑eye principle).
     

7. Third‑Party Integrations

Vendors, APIs, and cloud providers must contractually agree to equivalent CSAE detection & reporting standards.


8. Review Cycle

  • Immediate review after any policy breach or legislative change.


9. Governance & Contact

Child‑Safety Officer: Daichi Mitsuzawa (info@jelper.co)

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