Last updated: 17 June 2026
1. Atypikoo's commitment
Atypikoo is committed to protecting minors from all forms of exploitation, abuse or endangerment on its platform, in accordance with its French and European legal obligations:
- French Criminal Code: in particular Articles 227-22 (corruption of a minor), 227-22-1 (sexual propositions to a minor by means of electronic communication), 227-23 (child sexual abuse material), 227-24 (attacks on human dignity), 227-25 et seq. (sexual offences), 226-2-1 (non-consensual dissemination of intimate images), and 312-10 (blackmail);
- French Code of Criminal Procedure: Articles 7 (30-year limitation period from the victim's attainment of majority for sexual crimes against minors, Law 2018-703), 11 (confidentiality of investigations), and 706-47-3 (online undercover investigations);
- French Law for Confidence in the Digital Economy (LCEN): Article 6 (reporting illegal content and data retention);
- French Law 2024-449 (SREN) of 21 May 2024 aimed at securing and regulating the digital space;
- French Social Action and Families Code: Article L.226-2-1 (reporting to the CRIP);
- Regulation (EU) 2022/2065 (DSA): in particular Articles 16 (notice mechanisms), 18 (reporting suspected criminal offences), and 28 (online protection of minors);
- Directive 2011/93/EU on combating the sexual abuse and sexual exploitation of children, transposed into French law by Law 2013-711.
This policy is also guided by the principles of the United Nations Convention on the Rights of the Child (1989, Articles 19 and 34).
2. Platform exclusively reserved for adults
Atypikoo is a platform exclusively reserved for persons aged 18 or over. This restriction appears in the Terms of Use and is a condition of registration.
The following measures apply to any minor identified on the platform:
- deactivation of the account as soon as reasonably possible after the situation has actually been established, as an absolute priority and without prior notice;
- retention for 3 months of the information strictly necessary to document the decision, followed by its deletion, in accordance with the GDPR (Article 8 on children's consent) and the Privacy Policy;
- notification of the legal representative as soon as possible where they can be identified, unless such notification is likely to endanger the minor (for example, where there are indications of abuse within the family environment — Article 375 of the French Civil Code), in which case Atypikoo reports the matter to the Unit for Collecting Information of Concern (CRIP) or the Public Prosecutor (Article L.226-2-1 of the French Social Action and Families Code and Article 40 of the French Code of Criminal Procedure);
- notification of the legal representative is also deferred where required by the confidentiality of an investigation (Article 11 of the French Code of Criminal Procedure).
This compliance measure does not constitute a penalty within the meaning of Article 6 of the Moderation Charter, but fulfils a legal obligation of Atypikoo.
3. Strict prohibition of child sexual exploitation content
The following are strictly and absolutely prohibited on the platform, including but not limited to:
- capturing, recording, transmitting or disseminating an image of a minor where it is pornographic in nature, including by live broadcast (Article 227-23 of the French Criminal Code and paragraph 7 concerning streaming);
- corruption of a minor (Article 227-22 of the French Criminal Code);
- sexual propositions to a minor by means of electronic communication, known as grooming (Article 227-22-1 of the French Criminal Code);
- disseminating violent or pornographic messages, or messages likely to seriously undermine human dignity, which may be seen or perceived by a minor (Article 227-24 of the French Criminal Code);
- sexual offences against minors and sexual propositions to a minor (Article 227-25 et seq. of the French Criminal Code);
- sextortion (sexual blackmail — Articles 312-10 and 227-23 read together);
- soliciting the self-production of sexual content by a minor;
- any solicitation, facilitation of contact or approach strategy targeting a minor for sexual or exploitative purposes.
These prohibitions apply regardless of format (text, image, video, audio or live broadcast) and regardless of the technique used to produce the content. They expressly include content generated or altered using artificial intelligence ("deepfakes"), whether depicting an identifiable real minor or a character who appears to be a minor (Articles 226-8 and 226-8-1 of the French Criminal Code, as strengthened by the 2024 SREN Law).
4. How to report content or behaviour
4.1 Internal reporting
Internal reporting is free of charge and accessible without creating an account (a report may be anonymous, it being understood that a thorough investigation cannot be guaranteed in the absence of identifying information), and is available in French and English. Any Member or third party may immediately report suspicious content, a profile or behaviour:
- using the reporting tools built into the platform (the "…" button on profiles, messages, topics, events and comments);
- by email to the dedicated address: help02@atypikoo.com, with the subject line "URGENT — protection of minors".
4.2 Reporting to the authorities
Child sexual exploitation content may also be reported directly to:
- PHAROS (French Platform for Harmonisation, Analysis, Cross-checking and Guidance of Reports), the official French portal: www.internet-signalement.gouv.fr;
- e-Enfance / Net Écoute, a French helpline and reporting service: www.e-enfance.org — short number: 3018;
- INHOPE (European and international network of reporting hotlines): www.inhope.org;
- Internet Watch Foundation (IWF) (United Kingdom, European partner): www.iwf.org.uk.
5. Procedure for handling reports
Upon receiving a report concerning child sexual exploitation content or behaviour targeting a minor, Atypikoo applies the following procedure, in accordance with Article 16 of the DSA:
- Acknowledgement as soon as possible where the reporting person's identity is known. Reports concerning the safety of minors are handled as a priority, according to their seriousness and the available information;
- Immediate precautionary measure as soon as the content is found to be manifestly illegal: removal of the content, concealment of the profile or suspension of the relevant account, without awaiting the final decision;
- Reasoned decision issued by a human member of the team within a period that is reasonable in view of the seriousness of the report;
- Report to the competent authorities as soon as possible, in accordance with Articles 6-I-7 of the LCEN and 18 of the DSA, particularly through the PHAROS platform;
- Secure and differentiated retention of the necessary information:
- technical identification data (IP address and timestamp): retained for 12 months, in accordance with Decree 2021-1363 adopted pursuant to Article 6-II of the LCEN;
- information forwarded to the authorities (reported content, metadata and correspondence with PHAROS or the Public Prosecutor's Office): retained, where applicable, until the end of the legal proceedings, and no later than 30 years after the victim reaches the age of majority, in line with the limitation period for sexual crimes against minors (Article 7 of the French Code of Criminal Procedure, Law 2018-703);
- full terms: Privacy Policy.
- Permanent banning of the responsible account, under the conditions of Article 6.3 of the Moderation Charter (immediate ban for publishing child sexual abuse material) and Article 12 of the Terms of Use.
6. Cooperation with the authorities
Atypikoo cooperates fully with the judicial and administrative authorities and specialist organisations responsible for protecting minors and combating child sexual exploitation. This cooperation includes:
- forwarding information covered by judicial requests (Articles 60-1, 77-1-1 and 99-3 of the French Code of Criminal Procedure);
- proactively reporting to PHAROS and the competent authorities any manifestly illegal content relating to child sexual exploitation (Article 6 of the LCEN and Article 18 of the DSA);
- cooperating with specialist organisations (e-Enfance, La Voix de l'Enfant, etc.) in response to a substantiated request.
Authentication of requests. In accordance with good practices recommended by the CNIL, Atypikoo carries out a prior authenticity check on every judicial or administrative request:
- verification of the requesting person's capacity and identity (identification number of the criminal investigation officer and, in the event of doubt, a return call to the requesting department's official telephone line);
- verification of the legal basis relied upon (specific legal provision and classification of the relevant offence);
- requirement for a written and signed request;
- maintenance of an internal register of requests accessible to the data protection contact point (see Article 7).
Where there is any doubt as to the authenticity of a request, Atypikoo seeks written confirmation before transferring any data, in compliance with Article 11 of the French Code of Criminal Procedure.
In accordance with that same Article 11, the confidentiality of an investigation may result in notification to the Member concerned by a request being deferred.
7. Single DSA point of contact and officer responsible for the protection of minors
The address help02@atypikoo.com is Atypikoo's single point of contact for the purposes of:
- Article 11 of the DSA (point of contact for authorities);
- Article 12 of the DSA (point of contact for recipients of the service);
- this policy, for reports concerning the protection of minors.
This point of contact has the following characteristics:
- Address: help02@atypikoo.com (include "URGENT — protection of minors" for matters concerning minors);
- Languages accepted: French and English;
- Acknowledgement: as soon as possible for identified reports, with reports concerning the safety of minors handled as a priority.
Every request concerning the safety of minors is prioritised and handled with the utmost care.
8. Voluntary measures for the prevention and protection of minors
Although minors are prohibited from using the platform, and independently of any direct obligation under Article 28 of the DSA (from which micro and small enterprises are largely exempt under Article 19 of the DSA), Atypikoo voluntarily implements the following measures, adapted to its size and resources:
8.1 Age verification — a multi-layered approach
Registration is conditional on a prospective Member declaring that they are of legal age. Atypikoo recognises that this declaration represents the minimum level of verification and also implements subsequent detection measures:
- behavioural analysis using moderation support tools (vocabulary, connection times and profile consistency);
- reports by other Members or third parties;
- case-by-case identity checks based on a body of evidence, under the conditions of Article 5 of the Moderation Charter;
- any serious body of evidence indicating that a person is a minor results in immediate suspension of the account and a request for proof of identity under the conditions of the aforementioned Article 5.
Given the technical resources currently available to a platform of its size, Atypikoo is subject only to an obligation to use reasonable means when verifying age; it cannot guarantee the detection of false declarations. In line with developments in CNIL and ARCOM recommendations, Atypikoo regularly considers integrating an enhanced age-verification system (for example, a double-anonymity system compliant with the ARCOM standard) as soon as this becomes technically and economically viable.
8.1.1 False age declaration — liability and indemnification
Any person making a false declaration about their age when registering bears sole civil and criminal liability (Article 441-1 of the French Criminal Code — forgery of a private document). That person and, where applicable, their legal representatives shall hold Atypikoo SAS harmless and indemnify it against any claim, action, complaint or judgment brought by them or by a third party as a result of that false declaration and its consequences, unless they demonstrate gross personal negligence by Atypikoo in detecting that the person was a minor.
8.2 Moderation support tools and detection of high-risk behaviour
Moderation support tools are configured to process only behavioural indicators (vocabulary, approach patterns and profile anomalies) for the purposes of platform security, preventing abuse of vulnerable persons and complying with legal obligations to report to the competent authorities (in particular Article L.226-2-1 of the French Social Action and Families Code and Article 40 of the French Code of Criminal Procedure). If, incidentally and without this being sought in any way, such processing were to reveal data falling within Article 9 of the GDPR, it would remain limited to what is necessary for these security purposes and for compliance with Atypikoo's legal obligations. A data protection impact assessment (DPIA) is carried out and made available to the CNIL. No adverse decision is made without human review (Article 22 GDPR).
8.3 Other preventive measures
- Training for the moderation team in detecting signs of predatory approaches towards suspected minors;
- No targeted advertising on the platform;
- Enhanced cooperation with the authorities and specialist organisations (see Article 6).
9. Updates to this policy
- This policy is publicly available and dated.
- It may be updated to reflect changes in the legal framework, recommendations from the competent authorities (CNIL, ARCOM, MIVILUDES and the European Commission), and industry best practices.
- In the event of a material change, where possible Atypikoo informs Members by an appropriate means before it takes effect. Changes required by law, relating to security or the protection of minors, or consisting only of clarification with no adverse effect, may take effect immediately.