1. Introduction
FUNDAMENTAL COMMITMENT:
The safety of children and minors is the absolute and non-negotiable
priority of Shabon and its application
Bulle - European Social Media. We are committed to
creating and maintaining a safe, protected, and appropriate digital
environment for all our users, with particular vigilance regarding the
protection of minors.
1.1. About the Application
Bulle - European Social Media is a mobile and web
social media application developed and published by
SHABON, a simplified joint-stock company (SAS) with a
share capital of 19,191 euros, registered with the Paris Trade and
Companies Registry under number 993 549 971, with its registered
office at 10 rue de la Paix, 75002 Paris, France.
Legal information:
Company name: SHABON
SIRET: 99354997100014
Intra-community VAT: FR72993549971
Application name: Bulle - European Social Media
Developer: Shabon
General email:
Legal email:
1.2. Scope and Application
These Child Safety Standards apply to all users, content creators,
moderators, and partners of the
Bulle - European Social Media application. These
standards supplement and strengthen our
Terms of Use, our
Privacy Policy
and our Code of Ethics.
1.3. Commitment to Transparency
Shabon is committed to keeping these standards publicly accessible,
up to date, and functional at all times. Any substantial modification
will be communicated with 30 days' notice and will be clearly
notified to our users and the relevant authorities.
2. Zero Tolerance for CSAE (Child Sexual Abuse and Exploitation)
ABSOLUTE ZERO TOLERANCE POLICY
Shabon strictly, absolutely, and without any exception prohibits
all content, behavior, activity, or communication related in any
way to the sexual exploitation or sexual abuse of minors (Child
Sexual Abuse and Exploitation - CSAE).
2.1. Explicit Prohibition of CSAE
The application Bulle - European Social Media,
developed by Shabon, explicitly and categorically
prohibits:
-
All child sexual abuse material (Child Sexual Abuse
Material - CSAM)
: images, videos, texts, drawings, animations, or any other form
of representation
-
All sexual exploitation of minors in any form
whatsoever
-
All sexual solicitation of minors (grooming,
sextortion, blackmail)
-
All sexualization of minors: content that
presents, encourages, or normalizes sexual behavior involving
persons under 18 years of age
-
All predatory behavior toward minors:
inappropriate approaches, suspicious private contact requests,
manipulation attempts
-
All forms of trafficking or sexual commerce involving
minors
-
All glorification, trivialization, or encouragement of
such behavior
-
All sharing of information facilitating the
exploitation or abuse of minors
2.2. Immediate and Permanent Consequences
AUTOMATIC SANCTIONS:
Any violation of this zero tolerance policy results
immediately and without prior warning in:
-
The immediate and permanent removal of the
offending content
-
The permanent and irrevocable ban of the
offender's account
-
The
blocking of any new account creation (by
IP address, device, identity)
-
The mandatory and systematic reporting to the
relevant authorities:
-
National Center for Missing & Exploited Children (NCMEC) in
the United States
-
Pharos - Plateforme d'Harmonisation, d'Analyse, de Recoupement
et d'Orientation des Signalements (France)
- Procureur de la République (Public Prosecutor, France)
- Europol and relevant European authorities
-
The preservation of digital evidence for
transmission to judicial authorities
-
Full cooperation with any police or judicial
investigation
2.3. No Mitigating Circumstances
There are no circumstances, no context, and no
justification
that could mitigate, excuse, or legitimize any content or behavior
related to CSAE. This policy applies without exception to:
-
All users, regardless of their status (Standard, Verified,
Certified, Professional)
-
All types of content (public, private, direct messages,
comments)
- All forms of communication on the platform
- All territories and jurisdictions
3. Definitions
3.1. Minor
For the purposes of these safety standards, a
minor is any person under
18 years of age, in accordance with French and
European law. This definition applies regardless of the age of
majority in other jurisdictions.
3.2. CSAE (Child Sexual Abuse and Exploitation)
Child Sexual Abuse and Exploitation refers to any
act, behavior, content, or communication that:
-
Represents, facilitates, encourages, or normalizes sexual acts
involving minors
-
Sexually exploits a minor in any way whatsoever
- Solicits a minor for sexual purposes
- Sexualizes the image, appearance, or behavior of a minor
- Trades or traffics a minor for sexual purposes
3.3. CSAM (Child Sexual Abuse Material)
Child Sexual Abuse Material refers to any content
(image, video, text, audio, animation, drawing, etc.) that depicts
or describes:
- A minor engaged in explicit sexual activity
- A minor in a sexually suggestive pose or context
-
A sexualized depiction of a minor, even if artificially generated
(deepfake, AI, drawing)
-
Any content created for the purpose of sexually arousing the
viewer by depicting a minor
3.4. Grooming
Grooming (online predation) refers to the process
by which an adult establishes a relationship of trust with a minor
for the purpose of sexually exploiting them. This includes:
-
Establishing an emotional or affective bond to isolate the
victim
-
Progressive normalization of sexual conversations or content
- Requests for photos, videos, or personal information
- Attempts to arrange physical meetings in suspicious circumstances
3.5. Sextortion
Sextortion refers to the act of threatening or
blackmailing a minor by claiming to have access (real or alleged)
to compromising images or information about them, in order to
obtain:
- Sexual images or videos
- Sexual favors
- Money or goods
- Any other advantage under the threat of public disclosure
4. Strictly Prohibited Content
4.1. Prohibited Visual Content
ABSOLUTE PROHIBITION: The following content is
strictly prohibited on
Bulle - European Social Media:
-
Any image, video, or GIF depicting a minor in a sexual or
sexualized context
-
Any depiction of minor nudity, even partial or artistic
-
Any suggestive or provocative image of a minor (poses, clothing,
context)
-
Any AI-generated content or deepfake sexualizing a minor
-
Any drawing, animation, or manga of a sexual nature involving
minor or infantilized characters
-
Any screenshot or sharing of CSAM, even for the purpose of
reporting
4.2. Prohibited Textual Content
The following are strictly prohibited:
-
Any written description of sexual acts involving minors
(stories, fan fiction, "roleplay")
- Any sexual solicitation of a minor by message
-
Any proposal for a sexual encounter with a minor
- Any blackmail, threats, or sextortion attempts
- Any comment sexualizing a minor
- Any sharing of links to CSAM content
- Any glorification or normalization of pedophilia
4.3. Prohibited Behaviors
The following behaviors result in an immediate ban:
-
Grooming: establishing contact with a minor with sexual intent
-
Requesting photos, videos, or personal information of an intimate
nature from a minor
-
Offering money, gifts, or advantages in exchange for sexual
content
-
Attempting to arrange a suspicious physical meeting with a minor
-
Impersonating a minor in order to approach other minors
-
Sharing techniques or advice for exploiting minors
-
Recruiting, trafficking, or facilitating the sexual exploitation of minors
4.4. Prohibited Adjacent Content
Shabon also prohibits any content that, while not explicitly CSAM,
poses a risk to minors:
-
Content normalizing or trivializing adult-minor sexual
relationships
- Content portraying minors as sexual objects
-
Use of coded terms or euphemisms to refer to CSAE
-
Sharing methods to circumvent age protections and restrictions
-
Promotion of websites, platforms, or communities dedicated to CSAE
5. Age Restrictions and Verification
5.1. Minimum Registration Age
MINIMUM AGE: 13 YEARS
Registration on Bulle - European Social Media is
restricted to persons aged 13 years and older. This
restriction complies with European and French regulations (GDPR,
Loi Informatique et Libertés).
5.2. Mandatory Parental Consent
Minors aged 13 to 14 must obtain
explicit and verifiable consent from their parents
or legal guardians before creating an account. This consent is
verified through:
- Parental email confirmation
- Parent identity verification (official document)
- Electronic signature of the consent form
5.3. Progressive Verification System
Bulle uses a multi-level identity verification system to ensure the
actual age of users and adapt protections accordingly:
Standard Level (email only)
- Minimum verification: valid email address
- Age self-declared by the user (unverified)
- Maximum protections applied by default
- Content filtered at the most restrictive level (under 15)
Verified Level (phone)
- Phone number verification via SMS
- Age self-declared (not biometrically verified)
- Access to content adapted to the declared age
Certified Level (full identity)
-
Verification of an official identity document (ID card, passport)
via Stripe Identity and/or France Identité (French government service)
- Biometric verification (facial recognition)
- No identity document is stored by Shabon, only a unique identifier confirming the verification is retained
- Actual age guaranteed and verified
- Access to all features adapted to the verified age
-
Specific protections based on actual age (under 15, 15-17, 18+)
5.4. Detection and Reporting of False Ages
Shabon implements detection technologies to identify users who have
falsified their age:
- Behavioral and linguistic analysis
- Detection of inconsistencies in the information provided
- Community reporting of suspicious users
- Random checks by human moderation
Any user suspected of age fraud will have their account
immediately suspended until full identity
verification is completed.
6. Minor Protection Mechanisms
6.1. Usage Limitations and Curfews
To protect minors from addiction and prolonged exposure, Bulle
implements strict usage limitations:
Minors under 15:
- Maximum duration: 1 hour 30 minutes per day
-
Curfew: application inaccessible from 11:00 PM to 7:00 AM
(Standard/Verified accounts) or from 12:00 AM to 7:00 AM
(Certified accounts)
- Usage alert after 1 hour of continuous use
Minors aged 15 to 17:
- Maximum duration: 3 hours per day
- Curfew: application inaccessible from 12:00 AM to 6:00 AM
- Usage alert after 1 hour of continuous use
6.2. Age-Appropriate Content Filtering
Accessible content is strictly filtered based on the user's verified
or declared age:
-
Under 15: only content rated appropriate for
under 15 (no violence, sexuality, or inappropriate language)
-
15 to 17: access to 15+ content, exclusion of
18+ content
-
18 and over (Certified only): access to all
content, including 18+
6.3. Functional Restrictions for Minors
Minor accounts (non-Certified or Certified under 18) have
additional restrictions:
-
No private messages for Standard accounts
-
No public comments for Standard and Verified
accounts
-
Unable to publish videos (reserved for
Professional accounts, 18+ only)
-
Profile picture not allowed for Standard accounts
-
No access to dating or geolocation features
6.4. Automated Detection of Dangerous Content
Shabon uses advanced automated detection technologies:
-
PhotoDNA and other hash databases: instant
detection of known CSAM
-
Artificial Intelligence: analysis of new
suspicious content (images, videos, texts)
-
Facial recognition: approximate age detection in
visual content
-
Language analysis: detection of grooming, sexual
solicitations, threats
-
Behavioral detection: identification of
suspicious interaction patterns with minors
6.5. Automatic Blocking of Suspicious Interactions
The system automatically blocks and reports to moderation:
-
Private contact attempts from an unverified adult toward a minor
- Sending messages containing suspicious keywords
-
Requests for personal information (address, phone number,
location) from a minor
-
Sharing suspicious links or unverified external content
-
Repetitive or unusual behavior toward multiple minor accounts
6.6. Education and Awareness
Bulle regularly provides educational content to minors and their
parents:
-
Alerts on online risks (grooming, sextortion, cyberbullying)
- Safety and privacy guides
-
Resources for recognizing and reporting inappropriate behavior
-
Advice for parents on supervision and parental controls
6.5. Advertising and Algorithmic Protection
Bulle applies enhanced protections for minor users
regarding advertising and algorithmic personalization:
Advertising:
- No precise advertising targeting is applied to accounts under 18 years of age, no profiling
- No behavioral targeting (based on viewing history or reactions)
- No age or gender-based targeting
- No geographic targeting
- Advertisements shown to minors are selected entirely at random
Recommendation Algorithm:
- The default algorithm for minors is "Classic", which is generalist and not individually targeted
- A chronological mode is available, displaying publications in order of release without any relevance-based prioritization
- Legal guardians can manage available algorithms for their ward through parental controls
7. Reporting and Dedicated Contact
7.1. Built-in Reporting Mechanism
EASY AND ACCESSIBLE REPORTING:
Bulle - European Social Media has a
built-in reporting mechanism within the application,
accessible at any time and from any page, allowing users to report:
- Any suspicious or inappropriate content
- Any dangerous or predatory behavior
- Any suspicious user
- Any violation of the child safety standards
7.2. How to Report Content or Behavior
Users can report content or behavior in several ways:
A. Reporting via the application
-
"Report" button present on every piece of content
(video, comment, profile)
-
Reporting menu accessible from settings
-
Detailed form allowing users to specify the
nature of the violation
-
Anonymous reporting option to protect victims
-
Ability to attach screenshots or additional
evidence
B. Reporting by email
For serious or urgent cases, users can contact directly:
-
General reporting email:
-
Email dedicated to minor protection:
7.3. Dedicated Child Safety Contact
OFFICIAL CHILD SAFETY CONTACT
Shabon has designated a
dedicated child safety officer (Child
Safety Point of Contact) who:
-
Receives and processes all minor-related reports as a priority
- Coordinates responses to CSAM incidents
- Cooperates with authorities (police, judiciary, NCMEC, Pharos)
-
Oversees moderation procedures concerning minors
- Responds to requests from Google Play and regulators
Contact details:
Primary email:
Backup email:
Emergency phone: available upon request for authorities
Postal address: Shabon - Child Safety Officer, 10 rue de la Paix,
75002 Paris, France
7.4. Processing of Reports
All reports are processed with the highest priority:
-
CSAM reports: immediate processing (< 1 hour),
automatic blocking of the content and account, transmission to
authorities
-
Grooming or predatory behavior reports:
urgent investigation (< 24h), preventive suspension of the
suspect account
-
Other reports concerning minors: priority
review (< 48h)
- General reports: review within 72h
7.5. Protection of Reporters
Shabon guarantees:
-
Full confidentiality of the reporter's identity
-
No retaliation against good-faith reporters
-
Anonymous reporting option for sensitive cases
-
Victim protection: support, resources, referral
to assistance organizations
7.6. Decision Notification
The reporter receives a notification of the decision taken
(removal, ban, etc.) within
7 business days of the report, unless doing so
would compromise an ongoing investigation.
8. CSAM Content Management
8.1. Detection and Immediate Blocking
CSAM PROTOCOL - IMMEDIATE ACTION:
As soon as CSAM content is detected (by algorithm, human moderation,
or report), Shabon
immediately applies the
following measures:
- Instant blocking of the content (< 1 minute)
-
Permanent deletion from all servers and caches
-
Permanent ban of the account that published the
content
-
Tracing and preservation of digital evidence
(metadata, logs, IP)
-
Immediate reporting to authorities (NCMEC,
Pharos, Public Prosecutor)
8.2. Reporting to Relevant Authorities
In accordance with its legal obligations and ethical commitment,
Shabon systematically and without delay reports
every confirmed case of CSAM to the following authorities:
A. International Authorities
-
National Center for Missing & Exploited Children (NCMEC)
- United States
- Reporting via CyberTipline
- Transmission of detected CSAM hashes
- Cooperation for international investigations
-
Europol and INTERPOL for cross-border cases
B. French Authorities
-
Pharos (Plateforme d'Harmonisation, d'Analyse, de Recoupement et
d'Orientation des Signalements)
-
Procureur de la République de Paris (Public Prosecutor of Paris)
-
Filing of complaints and transmission of evidence for judicial
investigation
-
Brigade de Protection des Mineurs (BPM) (Minor Protection
Brigade) and specialized units of the Police Nationale
8.3. Evidence Preservation
Shabon preserves digital evidence of all detected CSAM content:
-
Cryptographic hash of the content (PhotoDNA, MD5,
SHA-256)
-
Complete metadata: date, time, account, IP,
device
- Activity logs of the suspect account
- Report history and interactions
This evidence is securely preserved and
transmitted only to judicial authorities upon
request or proactively as part of a report.
8.4. Full Cooperation with Investigations
Shabon is committed to cooperating
fully and without delay with any police or judicial
investigation concerning CSAE:
-
Response to judicial requests within
24 hours
- Transmission of all requested data and evidence
- Provision of technical experts for assistance
-
Testimony and participation in judicial proceedings if necessary
- Extended evidence preservation upon judicial request
8.5. Prevention of Recurrence
To prevent any return of an offender:
-
Permanent blacklist of identifiers, emails,
phone numbers, IP addresses
-
Device fingerprinting to block any
re-registration
-
CSAM hash sharing with NCMEC and international
databases
-
Continuous monitoring of circumvention attempts
9. Legal Compliance
9.1. Compliance with French Law
Bulle - European Social Media, developed by
Shabon, strictly complies with French laws relating
to the protection of minors, including:
-
Code Pénal (articles 227-23 to 227-31): suppression
of CSAM distribution, sexual exploitation and abuse of minors
-
Loi du 21 juin 2004 pour la confiance dans l'économie numérique
(LCEN)
: obligations of hosting providers regarding reporting and removal
of illegal content
-
Loi Informatique et Libertés (LIL) and
GDPR: protection of minors' personal data,
parental consent
-
Loi du 7 octobre 2016 pour une République numérique
: right to digital erasure for minors
-
Loi du 24 juillet 2020 visant à protéger les victimes de
violences conjugales
: reporting and protection provisions
9.2. GDPR Compliance
Shabon complies with the General Data Protection Regulation (GDPR)
regarding minors:
-
Mandatory parental consent for children under 15
(France) or 13 depending on jurisdiction
-
Data minimization for data collected on minors
-
Full transparency on data usage through our
Privacy Policy
-
Enhanced right to erasure for minors
-
Limitation of data retention period
-
Enhanced security of minors' data (encryption,
restricted access)
9.3. Digital Services Act (DSA) Compliance
As an online platform operating in the European Union, Shabon
complies with the Digital Services Act, including:
-
Transparency of moderation decisions: clear
notification of removals and bans
-
Right of appeal: ability to contest a decision
within 30 days
-
Easy and accessible reporting: visible and
functional reporting button
-
Annual transparency report: publication of
moderation and reporting statistics
-
Systemic risk assessment: regular audit of risks
to minors
9.4. Compliance with International Standards
Shabon also aligns with international standards:
-
United Nations Convention on the Rights of the Child
(UNCRC)
-
Optional Protocol on the sale of children, child prostitution,
and child pornography
-
OECD Recommendations on the protection of children
online
-
Safety by Design principles: security integrated
from the design stage
9.5. Audits and Certifications
Shabon is committed to:
-
Conducting regular security audits by independent
third parties
-
Obtaining and maintaining
compliance certifications (ISO 27001, etc.)
-
Publishing an
annual transparency report detailing minor
protection actions
-
Cooperating with regulators (CNIL, ARCOM, European Commission)
10. Proactive Moderation
10.1. Hybrid Moderation Approach
Shabon combines
automated moderation and human moderation to
ensure optimal protection of minors:
A. Automated Moderation (24/7)
-
Artificial Intelligence algorithms specifically
trained to detect:
- CSAM and sexually explicit content
- Grooming language and sexual solicitations
-
Predatory behaviors (suspicious interaction patterns)
- Apparent age in visual content
-
Hash databases (PhotoDNA, NCMEC) for instant
blocking of known CSAM
-
Keyword filters to detect inappropriate or coded
language
-
Behavioral analysis to identify suspicious
accounts
B. Specialized Human Moderation
-
Team of trained moderators specifically in minor
protection and CSAE detection
-
24/7 availability to handle urgent reports
-
Double verification of all automatically detected
CSAM cases
-
In-depth review of ambiguous or complex contexts
-
Psychological support for moderators exposed to
traumatic content
10.2. Continuous Moderator Training
All Shabon moderators receive
comprehensive and ongoing training on:
- Recognizing signs of CSAE and grooming
- Legal reporting obligations
- Emergency protocols for CSAM detection
- Cultural sensitivity and respect for privacy
- Stress management and vicarious trauma
10.3. Guaranteed Response Times
RESPONSIVENESS COMMITMENT:
- CSAM: immediate action (< 1 hour)
-
Grooming / sexual solicitation of a minor: <
24 hours
-
Inappropriate content for minors: < 48 hours
- Other reports: < 72 hours
10.4. Automatic Escalation
Serious cases are automatically escalated to:
-
The Child Safety Officer
- Shabon's legal department
- The relevant authorities (police, Pharos, NCMEC)
10.5. Continuous Improvement
Shabon is committed to continuously improving its moderation systems:
-
Regular analysis of false positives and false
negatives
-
Algorithm updates with the latest detection
techniques
- Integration of new CSAM hash databases
-
Moderator feedback to refine processes
-
Collaboration with experts (NGOs, researchers,
authorities)
11. Cooperation with Authorities
11.1. Commitment to Full Cooperation
Shabon is committed to cooperating fully, promptly, and without
reservation
with all relevant authorities in the fight against the sexual
exploitation and abuse of minors.
11.2. French Authorities
-
Pharos (Internet-Signalement.gouv.fr)
- Systematic reporting of all CSAM cases
- Transmission of digital evidence
- Response to information requests
-
Procureur de la République (Public Prosecutor)
- Filing of complaints for serious offenses
- Transmission of complete case files
-
Police Nationale and Gendarmerie
- Brigade de Protection des Mineurs (BPM) (Minor Protection Brigade)
-
Office Central pour la Répression des Violences aux Personnes
(OCRVP) (Central Office for the Suppression of Violence against Persons)
- Response to judicial requests within 24h
-
CNIL (Commission Nationale de l'Informatique et des
Libertés)
-
Compliance with minor data protection obligations
- Cooperation for audits and inspections
11.3. International Authorities
-
NCMEC (National Center for Missing & Exploited Children)
- United States
- Reporting via CyberTipline
- CSAM hash sharing
- Participation in prevention programs
-
Europol
- Cooperation for cross-border investigations
- Information sharing on CSAE networks
-
INTERPOL
-
International ICSE database (International Child Sexual
Exploitation)
- Assistance with worldwide investigations
11.4. Response to Judicial Requests
Shabon responds to judicial requests with the highest priority:
-
Response time: 24 hours maximum for urgent cases
(CSAM, abduction, imminent danger)
-
Secure transmission of all requested data (logs,
metadata, content, IP)
-
Evidence preservation: extended retention upon
judicial request
-
Technical testimony: provision of experts for
assistance
11.5. Proactive Reporting
Shabon makes proactive reports to authorities,
without waiting for a judicial request, for:
- All confirmed cases of CSAM
- Grooming or minor exploitation attempts
- Serious threats against minors
- Suspicious networks or communities dedicated to CSAE
11.6. Participation in Prevention Initiatives
Shabon actively participates in prevention and anti-CSAE
initiatives:
-
Collaboration with NGOs (Internet Watch Foundation, ECPAT, etc.)
-
Participation in industry working groups (Tech Coalition, etc.)
- Sharing best practices with other platforms
- Funding prevention and awareness programs
12. Transparency and Accountability
12.1. Annual Transparency Report
Shabon is committed to publishing an annual
Transparency Report detailing:
- Number of reports received (by category)
- Number of CSAM content detected and removed
-
Number of accounts banned for violation of child safety standards
-
Number of reports transmitted to authorities (Pharos, NCMEC, etc.)
- Average report processing times
- Automated moderation accuracy rate
- Improvements made to protection systems
12.2. Accessibility of these Standards
These Child Safety Standards are:
-
Publicly accessible at:
https://bulle.media/en/child-safety
-
Viewable without errors (permanent and functional
link)
-
Referenced in the Terms of Use, Privacy Policy,
and Code of Ethics
- Available in French and English
-
Regularly updated with notification of changes
12.3. Responsibility and Commitment
Shabon acknowledges its
moral, ethical, and legal responsibility in the
protection of minors on its platform. We are committed to:
-
Continuously investing in detection and prevention technologies
- Training and supporting our moderation teams
-
Listening and responding to the concerns of users, parents, and
organizations
- Constantly improving our standards and practices
-
Collaborating with the technology ecosystem for shared solutions
12.4. Feedback and Continuous Improvement
We encourage feedback to improve these standards:
-
Satisfaction surveys among users and parents
- Regular consultation with child protection experts
- Review of recommendations from authorities and regulators
- Analysis of incidents and failures to learn from them
12.5. Notification of Changes
Any substantial modification to these standards will be:
- Notified to users by email and in-app notification
- Communicated to Google Play and regulators
- Published with a minimum of 30 days' notice
- Documented with version history