Pre-incorporation notice. Venoly is run by its two founders and operated from Emmen, the Netherlands (the co-founder is based in the United States), while the legal entity (a Dutch B.V.) is being incorporated. Contracts and liabilities referenced in these documents are entered into by the founder personally until incorporation completes, at which point they transfer to Venoly B.V. by novation without action required from you. Where the documents refer to Venoly B.V., that name should be read as "Venoly (operating as a sole proprietorship pending incorporation)" until the entity is registered with the Dutch Chamber of Commerce (KvK).
1. Our Commitment
We have a zero-tolerance position on the sexual exploitation of children. CSAM is the single most serious category of content on the platform and the only one we treat as an absolute priority overriding every other operational consideration.
We design the platform to minimize the surface for such content, detect it when we encounter it, preserve evidence as required by law, and refer it to the appropriate national child-safety body.
2. Definitions
For the purpose of this policy, "CSAM" means:
- Any visual depiction — photograph, video, drawing, render, deepfake, or AI-generated image — of a minor engaged in sexually explicit conduct.
- Any sexually explicit content created using the likeness, voice, or persona of a person who was a minor at the time the underlying material was captured.
- Any content recruiting, soliciting, or directing minors into sexual activity, whether or not the content is itself sexually explicit.
The standard is the EU Directive 2011/93/EU on combating the sexual abuse and exploitation of children and child pornography (and the forthcoming EU CSAM Regulation, when applicable to us).
3. Detection
We detect CSAM through a layered approach:
- Reports from users — through the in-product report flow and the public Article 16 notice form.
- Human review — every child-safety report is reviewed by the founder.
- Uploads — every uploaded file is checked for malware. That check doesn't look for abuse material, and Venoly does not yet match uploads against lists of known abuse material.
Direct messages are not end-to-end encrypted. That is a deliberate choice: a report about a DM can be reviewed and acted on. Message text is not scanned; detection in DMs relies on user reports.
4. Response & Preservation
On confirmation of CSAM:
- Remove the content as soon as we see the report.
- Keep the report itself, including a sealed copy of a reported message's text.
- Terminate and deep-ban the uploading account.
- Report it by hand to the Offlimits Meldpunt, the Dutch reporting point, or to the police.
- Cooperate with subsequent law-enforcement requests under the Wetboek van Strafvordering, the EU Production Order Regulation (2023/1543), or equivalent.
5. Referrals
Where we report:
- Offlimits Meldpunt (Netherlands, formerly EOKM): meldpunt.offlimits.nl.
- The police (Netherlands): politie.nl, or 112 when a child is in danger right now.
- INHOPE network: inhope.org for jurisdictions covered by member hotlines.
Where we are required to refer to a national authority that is not on this list (e.g. an EU member state of the affected child), we will do so additionally.
6. Reporting CSAM to Us
If you have encountered CSAM on Venoly, you can report it via:
- The in-product Report button on any message, user, or server.
- The public form at /legal/report-content (anonymous reports accepted for CSAM under DSA Art. 16(2)).
- Email: safety@venoly.nl. The founder reads it, but email doesn't raise an alert.
Reports made with the Report button and the Child safety reason raise an alert for the founder. Venoly is run by one person: child-safety reports are handled before anything else, but we can't promise a response time. If a child is in danger right now, call 112.
7. Survivor Support
If you are a survivor of child sexual abuse and material depicting you appears on Venoly, please contact safety@venoly.nl directly. We will remove the material from Venoly. You can also use NCMEC's "Take It Down" or StopNCII yourself to help stop it spreading on other platforms that take part.