4.1 Content Review Approach
- No Proactive Monitoring: We do not systematically monitor customer content or communications
- Reactive Investigation: Content reviewed in response to abuse reports, legal requirements, or security concerns
- Automated Detection: Limited automated systems may flag potential violations for human review
- Manual Review: Trained staff review flagged content following established guidelines and legal requirements
4.1.1 Child Safety and CSAM Reporting
Upon obtaining actual knowledge of, or a report concerning, apparent child sexual abuse material (CSAM), online enticement, child sex trafficking, or another reportable child sexual exploitation offense on our services, we will preserve the relevant data and report to the National Center for Missing & Exploited Children (NCMEC) CyberTipline as required by 18 U.S.C. § 2258A.
We will cooperate with law enforcement and, where applicable, with child-safety regimes such as the UK Online Safety Act and EU requirements. Apparent CSAM is removed immediately and the responsible account is terminated. Our general practice of not proactively monitoring customer content (Section 4.1) does not limit these mandatory reporting and preservation obligations.
Where we become aware of information giving rise to a suspicion that a criminal offense involving a threat to the life or safety of a person has taken place, is taking place, or is likely to take place, and the EU Digital Services Act requires reporting, we will promptly inform the competent law-enforcement or judicial authorities and provide the relevant information available to us.
We provide unmanaged hosting infrastructure and do not have a general obligation to monitor content. On obtaining actual knowledge or awareness of illegal content through the reporting channels in Section 8, a valid authority order, or our own review, we act expeditiously to remove or disable access to it. We intend to conduct voluntary, good-faith investigations and the limited automated detection described in Section 4.1 consistently with any applicable intermediary-liability rules, including under the EU Digital Services Act.