CHILD SAFETY STANDARDS

Last Updated: April 2026

1. Our Commitment

myPalco maintains a zero-tolerance policy toward child sexual abuse and exploitation (CSAE) content and conduct on its platform. We are committed to ensuring the safety and well-being of all users, particularly minors. Any content, activity, or behavior that sexually exploits or endangers children is strictly prohibited and will result in immediate action, including permanent account termination and reporting to the relevant authorities.

2. Prohibited Content and Conduct

The following is strictly prohibited on myPalco:

• Any content that depicts, promotes, glorifies, or facilitates child sexual abuse or exploitation;
• Sharing, distributing, or soliciting child sexual abuse material (CSAM) in any form, including audio, images, video, text, or links;
• Grooming behavior, including any attempt by an adult to build a relationship with a minor for the purpose of sexual exploitation or abuse;
• Sextortion or any form of coercion or blackmail involving minors;
• Trafficking or any content or conduct that facilitates the trafficking of minors;
• Sexualization of minors in any form, including suggestive audio content, descriptions, or profile content;
• Soliciting personal information from minors for inappropriate purposes;
• Any other conduct that endangers the safety of children on or through the platform.

3. Age Requirements

myPalco requires all users to be at least 13 years of age to create an account. During registration, all new users must confirm their age. Users under 13 are not permitted to register independently; parental or guardian consent is required in accordance with Article 8 of the GDPR as transposed into Portuguese law.

myPalco reserves the right to terminate accounts where we have reason to believe the user does not meet the minimum age requirement.

4. Detection and Prevention

myPalco is committed to developing and improving its ability to detect and prevent CSAE content and conduct on the platform. Our current measures include:

• User reporting mechanisms that allow any user to flag content or conduct that may violate this policy;
• Manual review of all reports received, with priority given to child safety concerns;
• Age verification at registration to prevent underage access;
• Ongoing evaluation and adoption of additional detection tools and processes as the platform grows.

5. Reporting CSAE Content

We encourage all users to report any content or conduct that may constitute child sexual abuse or exploitation. Reports can be submitted through the following channels:

Email

Reports can be sent to: safety@mypalco.com

Please include as much detail as possible, including the username or profile link of the account in question and a description of the content or conduct being reported.

External Reporting

If you believe a child is in immediate danger, please contact your local law enforcement immediately. You may also report CSAE to:

• Policia Judiciaria (Portugal): www.policiajudiciaria.pt
• Linha Internet Segura (Safe Internet Line Portugal): www.internetsegura.pt / Phone: 800 21 90 90
• Missing Children Europe / Linha 116 000 (European missing children hotline)
• Internet Watch Foundation (IWF): www.iwf.org.uk

All reports are treated with the utmost confidentiality and urgency.

6. Enforcement Actions

When CSAE content or conduct is identified or reported, myPalco will take immediate action, which may include:

• Immediate removal of the offending content;
• Permanent suspension and termination of the offending account;
• Preservation of evidence related to the violation;
• Reporting the incident to the applicable law enforcement authorities, including the Policia Judiciaria in Portugal;
• Cooperation with law enforcement investigations as required by law;
• Reporting to relevant regulatory authorities, including the CNPD.

Account termination for CSAE violations is permanent and not subject to appeal.

7. Cooperation with Authorities

myPalco cooperates fully with law enforcement agencies, governmental bodies, and organizations dedicated to the protection of children. We comply with all applicable legal obligations regarding the reporting and preservation of information related to CSAE, including obligations under Portuguese law, EU law, and applicable international law.

Where required by law or where we have a good-faith belief that a child is at risk, myPalco will disclose relevant information to law enforcement without prior notice to the user.

8. Training and Accountability

All myPalco team members involved in reviewing user reports and moderating content are familiar with this Child Safety Standards policy and understand how to identify and respond to potential CSAE. We are committed to regularly reviewing and updating our child safety practices as the platform grows, in alignment with applicable legal requirements and guidance from child safety organizations.

9. Transparency

myPalco is committed to transparency in its child safety efforts. We may publish periodic reports on the actions taken to combat CSAE on our platform, including the volume of content removed and accounts terminated for policy violations.

10. Contact

For child safety concerns or inquiries regarding this policy:

Email: safety@mypalco.com

General legal inquiries: legal@mypalco.com

If you believe a child is in immediate danger, please contact local law enforcement immediately.